Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Order Granting Approval of Proposed Rule Change, as Modified by Amendment Nos. 1, 2, and 3 Thereto, Relating to the Listing and Trading of the Shares of the First Trust RiverFront Dynamic Europe ETF, First Trust RiverFront Dynamic Asia Pacific ETF, First Trust RiverFront Dynamic Emerging Markets ETF, and First Trust RiverFront Dynamic Developed International ETF of First Trust Exchange-Traded Fund III, 21626-21631 [2016-08307]
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21626
Federal Register / Vol. 81, No. 70 / Tuesday, April 12, 2016 / Notices
Comments may be submitted by any of
the following methods:
SECURITIES AND EXCHANGE
COMMISSION
Electronic Comments
[Release No. 34–77548; File No. SR–
NASDAQ–2015–161]
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NYSEMKT–2016–42 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
asabaliauskas on DSK3SPTVN1PROD with NOTICES
All submissions should refer to File
Number SR–NYSEMKT–2016–42. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NYSEMKT–2016–42 and should be
submitted on or before May 3, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.21
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–08304 Filed 4–11–16; 8:45 am]
BILLING CODE 8011–01–P
21 17
CFR 200.30–3(a)(12).
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Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Order
Granting Approval of Proposed Rule
Change, as Modified by Amendment
Nos. 1, 2, and 3 Thereto, Relating to
the Listing and Trading of the Shares
of the First Trust RiverFront Dynamic
Europe ETF, First Trust RiverFront
Dynamic Asia Pacific ETF, First Trust
RiverFront Dynamic Emerging Markets
ETF, and First Trust RiverFront
Dynamic Developed International ETF
of First Trust Exchange-Traded Fund III
April 6, 2016.
I. Introduction
On December 22, 2015, The NASDAQ
Stock Market LLC (‘‘Exchange’’ or
‘‘Nasdaq’’) filed with the Securities and
Exchange Commission (‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (‘‘Act’’
or Exchange Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
list and trade the shares of the First
Trust RiverFront Dynamic Europe ETF
(‘‘Europe Fund’’); First Trust RiverFront
Dynamic Asia Pacific ETF (‘‘Asia Pacific
Fund’’); First Trust RiverFront Dynamic
Emerging Markets ETF (‘‘Emerging
Markets Fund’’); and First Trust
RiverFront Dynamic Developed
International ETF (‘‘Developed
International Fund’’). The proposed rule
change was published for comment in
the Federal Register on January 8,
2016.3 On January 8, 2016, the Exchange
filed Amendment No. 1 to the proposed
rule change.4 On February 18, 2016, the
Exchange filed Amendment No. 2 to the
proposed rule change.5 On February 19,
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 76817
(January 4, 2016), 81 FR 978 (‘‘Notice’’).
4 In Amendment No. 1, the Exchange clarified the
proposed rule change by providing additional
information regarding the currencies, and
instruments that provide exposure to such
currencies, in which each Fund will invest. Because
Amendment No. 1 to the proposed rule change does
not materially alter the substance of the proposed
rule change or raise novel regulatory issues,
Amendment No. 1 is not subject to notice and
comment (Amendment No. 1 is available at: https://
www.sec.gov/comments/sr-nasdaq-2015-161/
nasdaq2015161-1.pdf).
5 In Amendment No. 2, the Exchange expanded
the application of the Alternative Criteria (as
discussed below) so that they will apply on a
continual basis. Because Amendment No. 2 does
not materially alter the substance of the proposed
rule change or raise novel regulatory issues,
Amendment No. 2 is not subject to notice and
comment (Amendment No. 2 is available at: http:
//www.sec.gov/comments/sr-nasdaq-2015-161/
nasdaq2015161-2.pdf).
2 17
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2016, pursuant to Section 19(b)(2) of the
Act,6 the Commission designated a
longer period within which to approve
the proposed rule change, disapprove
the proposed rule change, or institute
proceedings to determine whether to
disapprove the proposed rule change.7
On April 5, 2016, the Exchange filed
Amendment No. 3 to the proposed rule
change.8 The Commission received no
comments on the proposed rule change.
This order grants approval of the
proposed rule change, as modified by
Amendment Nos. 1, 2, and 3 thereto.
II. Exchange’s Description of the
Proposal
The Exchange proposes to list and
trade the shares (‘‘Shares’’) of the
Europe Fund, Asia Pacific Fund,
Emerging Markets Fund, and Developed
International Fund (individually,
‘‘Fund,’’ and collectively, ‘‘Funds’’)
under Nasdaq Rule 5735, which governs
the listing and trading of Managed Fund
Shares on the Exchange. Each Fund,
which will be a series of First Trust
Exchange-Traded Fund III (‘‘Trust’’),
will be an actively managed exchangetraded fund (‘‘ETF’’). The Shares will be
offered by the Trust,9 which was
established as a Massachusetts business
trust on January 9, 2008. The Trust is
registered with the Commission as an
investment company and has filed a
registration statement on Form N–1A
with the Commission.10
First Trust Advisors L.P. will be the
investment adviser (‘‘Adviser’’) to the
6 15
U.S.C. 78s(b)(2).
Securities Exchange Act Release No. 77192,
81 FR 9575 (February 25, 2016).
8 In Amendment No. 3 to the proposed rule
change, the Exchange clarified that: (a) All
statements and representations made in the
proposal regarding the description of the portfolios,
limitations on portfolio holdings or reference assets,
or the applicability of Exchange rules and
surveillance procedures shall constitute continued
listing requirements for listing the Shares on the
Exchange; (b) the issuer will advise the Exchange
of any failure by the Funds to comply with the
continued listing requirements; (c) pursuant to its
obligations under Section 19(g)(1) of the Act, the
Exchange will monitor for compliance with the
continued listing requirements; and (d) if a Fund is
not in compliance with the applicable listing
requirements, the Exchange will commence
delisting procedures under the Nasdaq 5800 Series.
Because Amendment No. 3 to the proposed rule
change does not materially alter the substance of
the proposed rule change or raise unique or novel
regulatory issues, Amendment No. 3 is not subject
to notice and comment (Amendment No. 3 is
available at: https://www.sec.gov/comments/srnasdaq-2015-161/nasdaq2015161-3.pdf).
9 According to the Exchange, the Trust has
obtained certain exemptive relief under the
Investment Company Act of 1940 (‘‘1940 Act’’). See
Investment Company Act Release No. 28468
(October 27, 2008) (File No. 812–13477).
10 See Post-Effective Amendment No. 29 to
Registration Statement on Form N–1A for the Trust,
dated November 19, 2015 (File Nos. 333–176976
and 811–22245) (‘‘Registration Statement’’).
7 See
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Funds. RiverFront Investment Group,
LLC will serve as investment subadviser (‘‘Sub-Adviser’’) to the Funds
and provide day-to-day portfolio
management. First Trust Portfolios L.P.
(‘‘Distributor’’) will be the principal
underwriter and distributor of each
Fund’s Shares. Brown Brothers
Harriman & Co. will act as the
administrator, accounting agent,
custodian, and transfer agent to the
Funds. According to the Exchange,
neither the Adviser nor the Sub-Adviser
is a broker-dealer, although the Adviser
is affiliated with the Distributor, a
broker-dealer, and the Sub-Adviser is
affiliated with Robert W. Baird & Co.
Incorporated, a broker-dealer. Each of
the Adviser and Sub-Adviser has
implemented a fire wall with respect to
its respective broker-dealer affiliate
regarding access to information
concerning the composition or changes
to a portfolio.11
The Exchange has made the following
representations and statements
describing the Funds and the Funds’
investment strategies, including the
Funds’ portfolio holdings and
investment restrictions.12
A. Exchange’s Description of Principal
Investment Strategies Applicable to
Each Fund
Each Fund’s investment objective will
be to provide capital appreciation.
Under normal market conditions,13 each
asabaliauskas on DSK3SPTVN1PROD with NOTICES
11 In
the event (a) the Adviser or the Sub-Adviser
registers as a broker-dealer, or becomes newly
affiliated with a broker-dealer, or (b) any new
adviser or sub-adviser is a registered broker-dealer
or becomes affiliated with another broker-dealer, it
will implement a fire wall with respect to its
relevant personnel and/or such broker-dealer
affiliate, as applicable, regarding access to
information concerning the composition of, and/or
changes to, a portfolio and will be subject to
procedures designed to prevent the use and
dissemination of material, non-public information
regarding such portfolio.
12 Additional information regarding the Funds,
the Trust, and the Shares, including investment
strategies, risks, creation and redemption
procedures, fees, portfolio holdings disclosure
policies, calculation of net asset value (‘‘NAV’’),
distributions, and taxes, among other things, can be
found in the Notice, the amendments, and the
Registration Statement, as applicable. See Notice,
Amendment Nos. 1–3, and Registration Statement,
supra notes 3, 4, 5, 8, and 10, respectively.
13 The term ‘‘under normal market conditions’’ as
used herein includes, but is not limited to, the
absence of adverse market, economic, political or
other conditions, including extreme volatility or
trading halts in the securities markets or the
financial markets generally; operational issues
causing dissemination of inaccurate market
information; or force majeure type events such as
systems failure, natural or man-made disaster, act
of God, armed conflict, act of terrorism, riot or labor
disruption, or any similar intervening circumstance.
On a temporary basis, including for defensive
purposes, during the initial invest-up period and
during periods of high cash inflows or outflows, a
Fund may depart from its principal investment
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Fund will seek to achieve its investment
objective by investing at least 80% of its
net assets (including investment
borrowings) in a combination of: (i)
‘‘Principal Fund Equity Securities’’ (as
defined below); (ii) forward currency
contracts and non-deliverable forward
currency contracts (collectively,
‘‘Forward Contracts’’); and (iii) currency
transactions on a spot (i.e., cash) basis.14
For each Fund, (a) ‘‘Principal Equity
Securities’’ will consist of the following
U.S. and non-U.S. exchange-listed
securities: (i) Common stocks; (ii)
common and preferred shares of real
estate investment trusts (‘‘REITs’’); and
(iii) American Depositary Receipts
(‘‘ADRs’’), European Depositary
Receipts (‘‘EDRs’’), and Global
Depositary Receipts (‘‘GDRs’’ and,
together with ADRs and EDRs,
collectively, ‘‘Depositary Receipts’’),15
and (b) ‘‘Principal Fund Equity
Securities’’ will consist of Principal
Equity Securities that are suggested by
such Fund’s name.16 Accordingly:
(1) For the Europe Fund, Principal
Fund Equity Securities will be Principal
Equity Securities of European
companies; 17
(2) for the Asia Pacific Fund,
Principal Fund Equity Securities will be
Principal Equity Securities of Asian
Pacific companies; 18
(3) for the Emerging Markets Fund,
Principal Fund Equity Securities will be
strategies; for example, it may hold a higher than
normal proportion of its assets in cash. During such
periods, a Fund may not be able to achieve its
investment objective. A Fund may adopt a
defensive strategy when the Adviser and/or the
Sub-Adviser believes securities in which such Fund
normally invests have elevated risks due to political
or economic factors and in other extraordinary
circumstances.
14 A Fund would enter into Forward Contracts
and/or currency spot transactions for hedging
purposes.
15 The Funds will not invest in any unsponsored
Depositary Receipts.
16 With respect to Depositary Receipts, whether
such Principal Equity Securities are Principal Fund
Equity Securities is based on the underlying
securities, the ownership of which is represented by
the Depositary Receipts (i.e., whether, as described
below, the relevant underlying security is a security
of a European company, an Asian Pacific company,
an emerging market company, or a developed
market company, as applicable).
17 European companies are those companies (i)
whose securities are traded principally on a stock
exchange in a European country, (ii) that are
organized under the laws of or have a principal
office in a European country, or (iii) that have at
least 50% of their assets in, or derive at least 50%
of their revenues or profits from, a European
country.
18 Asian Pacific companies are those companies
(i) whose securities are traded principally on a
stock exchange in an Asian Pacific country, (ii) that
are organized under the laws of or have a principal
office in an Asian Pacific country, or (iii) that have
at least 50% of their assets in, or derive at least 50%
of their revenues or profits from, an Asian Pacific
country.
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21627
Principal Equity Securities of emerging
market companies; 19 and
(4) for the Developed International
Fund, Principal Fund Equity Securities
will be Principal Equity Securities of
developed market companies.20
In selecting securities for a Fund, the
Sub-Adviser will score individual
securities from a portfolio of eligible
securities according to several core
attributes, using multiple proprietary
factors within each core attribute. The
Sub-Adviser will then rank each
qualifying security based on its core
attribute score, and the highest scoring
securities will be considered for
inclusion in the Fund’s portfolio. The
Sub-Adviser will utilize its proprietary
optimization process to maximize the
percentage of high-scoring securities
included in each Fund’s portfolio.
In addition, for each Fund, by
entering into Forward Contracts and
currency spot transactions, the SubAdviser will deploy a dynamic currency
hedge (hedging up to 100% of such
Fund’s foreign currency exposure) based
on its proprietary hedging methodology.
The Sub-Adviser’s hedging
methodology will be constructed from a
combination of quantitative measures
and qualitative measures. Each Fund
will only enter into transactions in
Forward Contracts with counterparties
that the Adviser and/or the Sub-Adviser
reasonably believe are capable of
performing under the applicable
Forward Contract.21
B. Exchange’s Description of Other
Investments for the Funds
According to the Exchange, each
Fund may invest (in the aggregate) up to
20% of its net assets in the following
securities and instruments.
19 An emerging market company is one (i)
domiciled or with a principal place of business or
primary securities trading market in an emerging
market country, or (ii) that derives a substantial
portion of its total revenues or profits from
emerging market countries.
20 Developed market companies are those
companies (i) whose securities are traded
principally on a stock exchange in a developed
market country, (ii) that are organized under the
laws of or have a principal office in a developed
market country, or (iii) that have at least 50% of
their assets in, or derive at least 50% of their
revenues or profits from, a developed market
country.
21 According to the Exchange, each Fund will
seek, where possible, to use counterparties, as
applicable, whose financial status is such that the
risk of default is reduced; however, the risk of
losses resulting from default is still possible. The
Adviser and/or the Sub-Adviser will evaluate the
creditworthiness of counterparties on an ongoing
basis. In addition to information provided by credit
agencies, the Adviser’s and/or Sub-Adviser’s
analysis will evaluate each approved counterparty
using various methods of analysis and may consider
the Adviser’s and/or Sub-Adviser’s past experience
with the counterparty, its known disciplinary
history, and its share of market participation.
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Each Fund may invest in the
following U.S. and non-U.S. exchangelisted securities (other than Principal
Fund Equity Securities): (i) Common
stocks; (ii) common and preferred shares
of REITs; (iii) Depositary Receipts; and
(iv) equity securities of business
development companies (collectively,
‘‘Other Equity Securities’’).22
Each Fund may invest in short-term
debt securities and other short-term debt
instruments (described below), as well
as cash equivalents, or it may hold cash.
The percentage of each Fund invested in
such holdings or held in cash will vary
and will depend on several factors,
including market conditions. Each Fund
may invest in the following short-term
debt instruments: 23 (1) Fixed rate and
floating rate U.S. government securities,
including bills, notes, and bonds
differing as to maturity and rates of
interest, which are either issued or
guaranteed by the U.S. Treasury or by
U.S. government agencies or
instrumentalities; (2) certificates of
deposit issued against funds deposited
in a bank or savings and loan
association; (3) bankers’ acceptances,
which are short-term credit instruments
used to finance commercial
transactions; (4) repurchase
agreements,24 which involve purchases
of debt securities; (5) bank time
deposits, which are monies kept on
deposit with banks or savings and loan
associations for a stated period of time
at a fixed rate of interest; (6) commercial
paper, which is short-term unsecured
promissory notes; 25 and (7) short-term
debt obligations issued or guaranteed by
non-U.S. governments or by their
agencies or instrumentalities.
Each Fund may invest (but only up to
5% of its net assets) in exchange-listed
equity index futures contracts.
22 For each Fund, Other Equity Securities and
Principal Fund Equity Securities are referred to
collectively as ‘‘Equity Securities.’’
23 The Exchange represents that short-term debt
instruments will be issued by issuers having a longterm debt rating of at least A by Standard & Poor’s
Ratings Services (‘‘S&P Ratings’’), Moody’s
Investors Service, Inc. (‘‘Moody’s’’), or Fitch Ratings
(‘‘Fitch’’), and have a maturity of one year or less.
24 According to the Exchange, each Fund intends
to enter into repurchase agreements only with
financial institutions and dealers believed by the
Adviser and/or the Sub-Adviser to present minimal
credit risks in accordance with criteria approved by
the Board of Trustees of the Trust. The Adviser and/
or the Sub-Adviser will review and monitor the
creditworthiness of such institutions. The Adviser
and/or the Sub-Adviser will monitor the value of
the collateral at the time the transaction is entered
into and at all times during the term of the
repurchase agreement. The Funds will not enter
into reverse repurchase agreements.
25 Each Fund may only invest in commercial
paper rated A–1 or higher by S&P Ratings, Prime1 or higher by Moody’s, or F1 or higher by Fitch.
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C. Exchange’s Description of the Funds’
Equity Securities
According to the Exchange, under
normal market conditions, each Fund
will invest in at least 20 Equity
Securities. Each Fund will satisfy the
‘‘ISG Criteria’’ (as described below) and/
or the ‘‘Alternative Criteria’’ (as
described below).
A Fund will satisfy the ISG Criteria if
at least 90% of such Fund’s net assets
that are invested (in the aggregate) in
Equity Securities will be invested in
Equity Securities that trade in markets
that are members of the Intermarket
Surveillance Group (‘‘ISG’’) 26 or are
parties to a comprehensive surveillance
sharing agreement with the Exchange.
A Fund will satisfy the Alternative
Criteria if, under normal market
conditions, its Equity Securities meet
the following criteria at the time of
purchase and on a continuous basis: (1)
Non-U.S. Equity Securities 27 each shall
have a minimum market value of at least
$100 million; (2) non-U.S. Equity
Securities each shall have a minimum
global monthly trading volume of
250,000 shares, or minimum global
notional volume traded per month of
$25,000,000, averaged over the last six
months; (3) the most heavily weighted
non-U.S. Equity Security shall not
exceed 25% of the weight of the Fund’s
entire portfolio and, to the extent
applicable, the five most heavily
weighted non-U.S. Equity Securities
shall not exceed 60% of the weight of
the Fund’s entire portfolio; (4) each nonU.S. Equity Security shall be listed and
traded on an exchange that has last-sale
reporting; and (5) all of such Fund’s net
assets that are invested (in the aggregate)
in Equity Securities other than non-U.S.
Equity Securities shall be invested in
Equity Securities that trade in markets
that are members of ISG or are parties
to a comprehensive surveillance sharing
agreement with the Exchange.
D. Exchange’s Description of the Funds’
Transactions in Forward Contracts and
Exchange-Listed Equity Index Futures
Contracts
According to the Exchange, each
Fund’s transactions in Forward
Contracts and exchange-listed equity
index futures contracts will be
consistent with its investment objective
and the 1940 Act and will not be used
26 For a list of the current members of ISG, see
www.isgportal.org. The Exchange notes that not all
components of the Disclosed Portfolio for a Fund
may trade on markets that are members of ISG or
with which the Exchange has in place a
comprehensive surveillance sharing agreement.
27 For purposes of this filing, the term ‘‘non-U.S.
Equity Securities’’ means Equity Securities that are
not listed on a U.S. exchange.
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Fmt 4703
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to seek to achieve a multiple or inverse
multiple of an index. Each Fund will
comply with the regulatory
requirements of the Commission with
respect to coverage in connection with
its transactions in Forward Contracts
and exchange-listed equity index
futures contracts. If the applicable
guidelines prescribed under the 1940
Act so require, a Fund will earmark
cash, U.S. government securities and/or
other liquid assets permitted by the
Commission in the amount prescribed.
E. Exchange’s Description of the Funds’
Investment Restrictions
Each Fund may hold up to an
aggregate amount of 15% of its net
assets in illiquid assets (calculated at
the time of investment), deemed illiquid
by the Adviser and/or the SubAdviser.28 Each Fund will monitor its
portfolio liquidity on an ongoing basis
to determine whether, in light of current
circumstances, an adequate level of
liquidity is being maintained, and will
consider taking appropriate steps in
order to maintain adequate liquidity if,
through a change in values, net assets,
or other circumstances, more than 15%
of such Fund’s net assets are held in
illiquid assets. Illiquid assets include
securities subject to contractual or other
restrictions on resale and other
instruments that lack readily available
markets as determined in accordance
with Commission staff guidance.
The Funds may not invest 25% or
more of the value of their respective
total assets in securities of issuers in any
one industry. This restriction does not
apply to (a) obligations issued or
guaranteed by the U.S. government, its
agencies or instrumentalities, or (b)
securities of other investment
companies.
Each Fund intends to qualify each
year as a regulated investment company
under Subchapter M of the Internal
Revenue Code.
III. Discussion and Commission
Findings
After careful review, the Commission
finds that the Exchange’s proposal is
consistent with the Exchange Act and
the rules and regulations thereunder
28 According to the Exchange, in determining the
liquidity of the Funds’ investments, the Adviser
and/or the Sub-Adviser may consider the following
factors: (i) The frequency of trades and quotes for
the security or other instrument; (ii) the number of
dealers wishing to purchase or sell the security or
other instrument and the number of other potential
purchasers; (iii) dealer undertakings to make a
market in the security or other instrument; and (iv)
the nature of the security or other instrument and
the nature of the marketplace in which it trades
(e.g., the time needed to dispose of the security or
other instrument, the method of soliciting offers
and the mechanics of transfer).
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applicable to a national securities
exchange.29 In particular, the
Commission finds that the proposed
rule change, as modified by Amendment
Nos. 1, 2, and 3 thereto, is consistent
with Section 6(b)(5) of the Exchange
Act,30 which requires, among other
things, that the Exchange’s rules be
designed to promote just and equitable
principles of trade, to remove
impediments to and perfect the
mechanism of a free and open market
and a national market system, and, in
general, to protect investors and the
public interest.
The Commission also finds that the
proposal is consistent with Section
11A(a)(1)(C)(iii) of the Exchange Act,31
which sets forth Congress’s finding that
it is in the public interest and
appropriate for the protection of
investors and the maintenance of fair
and orderly markets to assure the
availability to brokers, dealers, and
investors of information with respect to
quotations for, and transactions in,
securities.
Quotation and last-sale information
for the Shares will be available via
Nasdaq proprietary quote and trade
services, as well as in accordance with
the Unlisted Trading Privileges and the
Consolidated Tape Association (‘‘CTA’’)
plans for the Shares. On each business
day, before commencement of trading in
Shares in the Regular Market Session 32
on the Exchange, each Fund will
disclose on its Web site the Disclosed
Portfolio held by such Fund that will
form the basis for such Fund’s
calculation of NAV at the end of the
business day.33 The NAV of each Fund’s
29 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
30 15 U.S.C. 78f(b)(5).
31 15 U.S.C. 78k–1(a)(1)(C)(iii).
32 See Nasdaq Rule 4120(b)(4) (describing the
three trading sessions on the Exchange: (1) PreMarket Session from 4:00 a.m. to 9:30 a.m., Eastern
Time; (2) Regular Market Session from 9:30 a.m. to
4:00 p.m. or 4:15 p.m., Eastern Time; and (3) PostMarket Session from 4:00 p.m. or 4:15 p.m. to 8:00
p.m., Eastern Time).
33 Nasdaq Rule 5735(c)(2) defines the term
‘‘Disclosed Portfolio.’’ According to the Exchange,
each Fund’s disclosure of derivative positions in
the Disclosed Portfolio will include sufficient
information for market participants to use to value
these positions intraday. On a daily basis, each
Fund will also disclose on its Web site the
following information regarding each portfolio
holding, as applicable to the type of holding: ticker
symbol, CUSIP number or other identifier, if any;
a description of the holding (including the type of
holding); the identity of the security, index, or other
asset or instrument underlying the holding, if any;
quantity held (as measured by, for example, par
value, notional value, or number of shares,
contracts, or units); maturity date, if any; coupon
rate, if any; effective date, if any; market value of
the holding; and percentage weighting of the
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Shares generally will be calculated once
daily Monday through Friday as of the
close of regular trading on the New York
Stock Exchange, generally 4:00 p.m.,
Eastern Time.34
In addition, the Intraday Indicative
Value 35 for each Fund, available on the
NASDAQ OMX Information LLC
proprietary index data service, will be
based upon the current value for the
components of the Disclosed Portfolio
and will be updated and widely
disseminated by one or more major
holding in the Fund’s portfolio. The Web site
information will be publicly available at no charge.
34 According to the Exchange, the Funds’
investments will be valued daily. The following
investments will typically be valued using
information provided by a third-party pricing
service (‘‘Pricing Service’’): (a) Except as provided
below, short term U.S. government securities,
commercial paper, bankers’ acceptances, and shortterm debt obligations issued or guaranteed by nonU.S. governments or by their agencies or
instrumentalities (collectively, ‘‘Short Term Debt
Instruments’’); and (b) currency spot transactions.
Debt instruments may be valued at evaluated mean
prices, as provided by Pricing Services. Short Term
Debt Instruments having a remaining maturity of 60
days or less when purchased will typically be
valued at cost adjusted for amortization of
premiums and accretion of discounts, provided the
pricing committee of the Adviser (‘‘Pricing
Committee’’) has determined that the use of
amortized cost is an appropriate reflection of value
given market and issuer specific conditions existing
at the time of the determination. Overnight
repurchase agreements will be valued at amortized
cost when it represents the best estimate of value.
Term repurchase agreements (i.e., those whose
maturity exceeds seven days) will be valued at the
average of the bid quotations obtained daily from
at least two recognized dealers. Certificates of
deposit and bank time deposits will typically be
valued at cost. Equity Securities that are listed on
any exchange other than the Exchange and the
London Stock Exchange Alternative Investment
Market (‘‘AIM’’) will typically be valued at the lastsale price on the exchange on which they are
principally traded on the business day as of which
such value is being determined. Equity Securities
listed on the Exchange or the AIM will typically be
valued at the official closing price on the business
day as of which such value is being determined. If
there has been no sale on such day, or no official
closing price in the case of securities traded on the
Exchange or the AIM, such securities will typically
be valued using fair value pricing. Equity Securities
traded on more than one securities exchange will
be valued at the last sale price or official closing
price, as applicable, on the business day as of
which such value is being determined at the close
of the exchange representing the principal market
for such securities. Exchange-listed equity index
futures contracts will typically be valued at the
closing price in the market where such instruments
are principally traded. Forward Contracts will
typically be valued at the current day’s interpolated
foreign exchange rate, as calculated using the
current day’s spot rate, and the thirty, sixty, ninety,
and one-hundred-eighty day forward rates provided
by a Pricing Service or by certain independent
dealers in such contracts. Assets denominated in
foreign currencies will be translated into U.S.
dollars at the exchange rate of such currencies
against the U.S. dollar as provided by a Pricing
Service. The value of assets denominated in foreign
currencies will be converted into U.S. dollars at the
exchange rates in effect at the time of valuation.
35 Nasdaq Rule 5735(c)(3) defines the term
‘‘Intraday Indicative Value.’’
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21629
market data vendors and broadly
displayed at least every 15 seconds
during the Regular Market Session. The
Intraday Indicative Value will be based
on quotes and closing prices from the
securities’ local market and may not
reflect events that occur subsequent to
the local market’s close.
Information regarding market price
and trading volume of the Shares will be
continually available on a real-time
basis throughout the day on brokers’
computer screens and other electronic
services. Information regarding the
previous day’s closing price and trading
volume information for the Shares will
be published daily in the financial
section of newspapers. Quotation and
last-sale information for the Equity
Securities (to the extent traded on a U.S.
exchange) will be available from the
exchanges on which they are traded as
well as in accordance with any
applicable CTA plans. Pricing
information for Short-Term Debt
Instruments, repurchase agreements,
Forward Contracts, bank time deposits,
certificates of deposit, and currency spot
transactions will be available from
major broker-dealer firms and/or major
market data vendors and/or Pricing
Services. Pricing information for
exchange-listed equity index futures
contracts and non-U.S. Equity Securities
will be available from the applicable
listing exchange and from major market
data vendors. In addition, the Exchange
notes that the Funds’ Web site will
include a form of the prospectus for the
Funds and additional data relating to
NAV and other applicable quantitative
information.
The Commission also believes that the
proposal to list and trade the Shares is
reasonably designed to promote fair
disclosure of information that may be
necessary to price the Shares
appropriately and to prevent trading
when a reasonable degree of
transparency cannot be assured. The
Exchange states that it will obtain a
representation from the issuer of the
Shares that the NAV per Share will be
calculated daily and that the NAV and
the Disclosed Portfolio will be made
available to all market participants at
the same time. The Exchange also
represents that it may consider all
relevant factors in exercising its
discretion to halt or suspend trading in
the Shares of a Fund. The Exchange will
halt trading in the Shares under the
conditions specified in Nasdaq Rules
4120 and 4121, including the trading
pauses under Nasdaq Rules 4120(a)(11)
and (12). Trading may be halted because
of market conditions or for reasons that,
in the view of the Exchange, make
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trading in the Shares inadvisable.36
Trading in the Shares also will be
subject to Rule 5735(d)(2)(D), which sets
forth circumstances under which Shares
of a Fund may be halted.
The Exchange states that it has a
general policy prohibiting the
distribution of material, non-public
information by its employees. The
Exchange further states that neither the
Adviser nor the Sub-Adviser is a brokerdealer, but each is affiliated with a
broker-dealer, and that the Adviser and
Sub-Adviser has each implemented a
fire wall with respect to its respective
broker-dealer affiliate regarding access
to information concerning the
composition of, and changes to, each
Fund’s portfolio.37 Further, the
Commission notes that the Reporting
Authority 38 that provides the Disclosed
Portfolio must implement and maintain,
or be subject to, procedures designed to
prevent the use and dissemination of
material, non-public information
regarding the actual components of the
portfolio.39 The Exchange represents
that trading in the Shares will be subject
to the existing trading surveillances,
administered by both Nasdaq and also
the Financial Industry Regulatory
Authority (‘‘FINRA’’) on behalf of the
Exchange, which are designed to detect
36 These may include: (1) The extent to which
trading is not occurring in the securities and/or the
other assets constituting the Disclosed Portfolio of
a Fund; or (2) whether other unusual conditions or
circumstances detrimental to the maintenance of a
fair and orderly market are present.
37 See supra note 11 and accompanying text. The
Exchange further represents that an investment
adviser to an open-end fund is required to be
registered under the Investment Advisers Act of
1940 (‘‘Advisers Act’’). As a result, the Adviser, the
Sub-Adviser, and their related personnel are subject
to the provisions of Rule 204A–1 under the
Advisers Act relating to codes of ethics. This Rule
requires investment advisers to adopt a code of
ethics that reflects the fiduciary nature of the
relationship to clients as well as compliance with
other applicable securities laws. Accordingly,
procedures designed to prevent the communication
and misuse of non-public information by an
investment adviser must be consistent with Rule
204A–1 under the Advisers Act. In addition, Rule
206(4)–7 under the Advisers Act makes it unlawful
for an investment adviser to provide investment
advice to clients unless such investment adviser has
(i) adopted and implemented written policies and
procedures reasonably designed to prevent
violation, by the investment adviser and its
supervised persons, of the Advisers Act and the
Commission rules adopted thereunder; (ii)
implemented, at a minimum, an annual review
regarding the adequacy of the policies and
procedures established pursuant to subparagraph (i)
above and the effectiveness of their
implementation; and (iii) designated an individual
(who is a supervised person) responsible for
administering the policies and procedures adopted
under subparagraph (i) above.
38 Nasdaq Rule 5735(c)(4) defines ‘‘Reporting
Authority.’’
39 See Nasdaq Rule 5735(d)(2)(B)(ii).
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violations of Exchange rules and
applicable federal securities laws.40
Nasdaq deems the Shares to be equity
securities, thus rendering trading in the
Shares subject to Nasdaq’s existing rules
governing the trading of equity
securities. In support of this proposal,
the Exchange represented that:
(1) The Shares will be subject to
Nasdaq Rule 5735, which sets forth the
initial and continued listing criteria
applicable to Managed Fund Shares.
(2) Trading in the Shares will be
subject to the existing trading
surveillances, administered by both
Nasdaq and FINRA on behalf of the
Exchange, which are designed to detect
violations of Exchange rules and
applicable federal securities laws. The
Exchange represents that these
procedures are adequate to properly
monitor Exchange trading of the Shares
in all trading sessions and to deter and
detect violations of Exchange rules and
applicable federal securities laws.
(3) FINRA, on behalf of the Exchange,
will communicate as needed regarding
trading in the Shares and certain of the
Equity Securities and exchange-listed
equity index futures contracts held by
the Funds with other markets and other
entities that are members of ISG, and
FINRA may obtain trading information
regarding trading in the Shares and such
securities and instruments held by the
Funds from such markets and other
entities. In addition, the Exchange may
obtain information regarding trading in
the Shares and certain of the Equity
Securities and exchange-listed equity
index futures contracts held by the
Funds from markets and other entities
that are members of ISG, which includes
securities and futures exchanges, or
with which the Exchange has in place
a comprehensive surveillance sharing
agreement. Moreover, FINRA, on behalf
of the Exchange, will be able to access,
as needed, trade information for certain
fixed income securities held by the
Funds reported to FINRA’s Trade
Reporting and Compliance Engine
(‘‘TRACE’’).
(4) For each Fund, at least 90% of
such Fund’s net assets that are invested
(in the aggregate) in exchange-listed
equity index futures contracts will be
invested in instruments that trade in
markets that are members of ISG or are
parties to a comprehensive surveillance
sharing agreement with the Exchange.
(5) The Exchange has appropriate
rules to facilitate transactions in the
Shares during all trading sessions.
40 The Exchange represents that FINRA surveils
trading on the Exchange pursuant to a regulatory
services agreement and that the Exchange is
responsible for FINRA’s performance under this
regulatory services agreement.
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(6) Prior to the commencement of
trading, the Exchange will inform its
members in an Information Circular of
the special characteristics and risks
associated with trading the Shares.
Specifically, the Information Circular
for each Fund will discuss the
following: (a) The procedures for
purchases and redemptions of Shares in
Creation Units (and that Shares are not
individually redeemable); (b) Nasdaq
Rule 2111A, which imposes suitability
obligations on Nasdaq members with
respect to recommending transactions in
the Shares to customers; (c) how
information regarding the Intraday
Indicative Value and the Disclosed
Portfolio is disseminated; (d) the risks
involved in trading the Shares during
the Pre-Market and Post-Market
Sessions when an updated Intraday
Indicative Value will not be calculated
or publicly disseminated; (e) the
requirement that members deliver a
prospectus to investors purchasing
newly issued Shares prior to or
concurrently with the confirmation of a
transaction; and (f) trading information.
(7) For initial and continued listing,
the Funds must be in compliance with
Rule 10A–3 under the Act.41
(8) Each Fund may hold up to an
aggregate amount of 15% of its net
assets in illiquid assets.
(9) The Pricing Committee will be
subject to procedures designed to
prevent the use and dissemination of
material non-public information
regarding each Fund’s portfolio.
(10) Each Fund will satisfy: (a) The
ISG Criteria; and/or (b) the Alternative
Criteria at the time of purchase and on
a continuous basis.
(11) A minimum of 100,000 Shares
will be outstanding at the
commencement of trading on the
Exchange.
The Exchange represents that all
statements and representations made in
the filing regarding (a) the description of
the portfolios, (b) limitations on
portfolio holdings or reference assets, or
(c) the applicability of Exchange rules
and surveillance procedures shall
constitute continued listing
requirements for listing the Shares on
the Exchange. In addition, the issuer has
represented to the Exchange that it will
advise the Exchange of any failure by
the Funds to comply with the continued
listing requirements, and, pursuant to
its obligations under Section 19(g)(1) of
the Act, the Exchange will monitor for
compliance with the continued listing
requirements.42 If a Fund is not in
41 See
17 CFR 240.10A–3.
Commission notes that certain other
proposals for the listing and trading of Managed
42 The
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compliance with the applicable listing
requirements, the Exchange will
commence delisting procedures under
the Nasdaq 5800 Series. This approval
order is based on all of the Exchange’s
representations, including those set
forth above, in the Notice, and in
Amendment Nos. 1, 2, and 3 to the
proposed rule change. The Commission
notes that the Funds and the Shares
must comply with the requirements of
Nasdaq Rule 5735, including those set
forth in this proposed rule change, as
modified by Amendment Nos. 1, 2, and
3 thereto, to be listed and traded on the
Exchange on an initial and continuing
basis.
For the foregoing reasons, the
Commission finds that the proposed
rule change, as modified by Amendment
Nos. 1, 2, and 3 thereto, is consistent
with Section 6(b)(5) of the Act 43 and the
rules and regulations thereunder
applicable to a national securities
exchange.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,44
that the proposed rule change (SR–
NASDAQ–2015–161), as modified by
Amendment Nos. 1, 2, and 3 thereto, be,
and it hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.45
Robert W. Errett,
Deputy Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77545; File No. SR–Phlx–
2016–44]
Self-Regulatory Organizations;
NASDAQ PHLX LLC; Notice of Filing
and Immediate Effectiveness of
Proposed Rule ChangeTo Amend Rule
1064
April 6, 2016.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 1,
2016, NASDAQ PHLX LLC (‘‘Phlx’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III, below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to delete two
incorrect cross-references in Rule 1064,
Crossing, Facilitation and Solicited
Orders.
The text of the proposed rule change
is detailed below: Proposed new
language is in italics and proposed
deletions are in brackets.
*
*
*
*
*
NASDAQ PHLX Rules
[FR Doc. 2016–08307 Filed 4–11–16; 8:45 am]
*
BILLING CODE 8011–01–P
*
*
*
*
Options Rules
Rules Applicable To Trading of Options
on Stocks, Exchange-Traded Fund
Shares and Foreign Currencies (Rules
1000–1095)
asabaliauskas on DSK3SPTVN1PROD with NOTICES
*
Fund Shares include a representation that the
exchange will ‘‘surveil’’ for compliance with the
continued listing requirements. See, e.g.,
Amendment No. 2 to SR–BATS–2016–04, available
at: https://www.sec.gov/comments/sr-bats-2016-04/
bats201604-2.pdf. In the context of this
representation, it is the Commission’s view that
‘‘monitor’’ and ‘‘surveil’’ both mean ongoing
oversight of the Fund’s compliance with the
continued listing requirements. Therefore, the
Commission does not view ‘‘monitor’’ as a more or
less stringent obligation than ‘‘surveil’’ with respect
to the continued listing requirements.
43 15 U.S.C. 78f(b)(5).
44 15 U.S.C. 78s(b)(2).
45 17 CFR 200.30–3(a)(12).
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*
*
*
*
Rule 1064. Crossing, Facilitation and
Solicited Orders
(a)–(c) No change.
(d) No change.
(i)–(ii) No change.
(iii) No change.
(A)–(F) No change.
(G) prior to entering tied hedge orders
on behalf of customers, the member or
member organization must deliver to the
customer a written notification
informing the customer that his order
may be executed using the Exchange’s
tied hedge procedures. The written
notification must disclose the terms and
conditions contained [in this
1 15
2 17
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00099
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21631
Commentary] herein and be in a form
approved by the Exchange. A
combination option and hedging
position offered in reliance on this
[Commentary .04] provision shall be
referred to as a ‘‘tied hedge’’ order.
(H)–(I) No change.
(e) No change.
• • • Commentary: -----------------.01–.02 No change.
*
*
*
*
*
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of the filing is to correct
Rule 1064 by deleting two references to
the ‘‘commentary’’ to the rule, which no
longer exists. The Exchange recently
deleted Commentary .04 3 by
incorporating its provisions into
paragraph (d)(iii), because it was related
to the anticipatory hedging provisions
in paragraph (d). The Exchange
inadvertently omitted the deletion of
these two references to Commentary .04
in new Rule 1064(d)(iii)(G).
Accordingly, this provision refers to a
commentary that does not exist.
2. Statutory Basis
The Exchange believes that its
proposal is consistent with Section 6(b)
of the Act 4 in general, and furthers the
objectives of Section 6(b)(5) of the Act 5
in particular, in that it is designed to
promote just and equitable principles of
trade and to protect investors and the
public interest by correcting a provision,
which should help prevent confusion
and ensure the accuracy of the rulebook.
3 Securities Exchange Act Release No. 76984
(January 28, 2016), 81 FR 5796 (February 3, 2016)
(SR–Phlx–2016–07).
4 15 U.S.C. 78f(b).
5 15 U.S.C. 78f(b)(5).
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[Federal Register Volume 81, Number 70 (Tuesday, April 12, 2016)]
[Notices]
[Pages 21626-21631]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-08307]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-77548; File No. SR-NASDAQ-2015-161]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Order
Granting Approval of Proposed Rule Change, as Modified by Amendment
Nos. 1, 2, and 3 Thereto, Relating to the Listing and Trading of the
Shares of the First Trust RiverFront Dynamic Europe ETF, First Trust
RiverFront Dynamic Asia Pacific ETF, First Trust RiverFront Dynamic
Emerging Markets ETF, and First Trust RiverFront Dynamic Developed
International ETF of First Trust Exchange-Traded Fund III
April 6, 2016.
I. Introduction
On December 22, 2015, The NASDAQ Stock Market LLC (``Exchange'' or
``Nasdaq'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'' or Exchange Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to list and trade the shares of
the First Trust RiverFront Dynamic Europe ETF (``Europe Fund''); First
Trust RiverFront Dynamic Asia Pacific ETF (``Asia Pacific Fund'');
First Trust RiverFront Dynamic Emerging Markets ETF (``Emerging Markets
Fund''); and First Trust RiverFront Dynamic Developed International ETF
(``Developed International Fund''). The proposed rule change was
published for comment in the Federal Register on January 8, 2016.\3\ On
January 8, 2016, the Exchange filed Amendment No. 1 to the proposed
rule change.\4\ On February 18, 2016, the Exchange filed Amendment No.
2 to the proposed rule change.\5\ On February 19, 2016, pursuant to
Section 19(b)(2) of the Act,\6\ the Commission designated a longer
period within which to approve the proposed rule change, disapprove the
proposed rule change, or institute proceedings to determine whether to
disapprove the proposed rule change.\7\ On April 5, 2016, the Exchange
filed Amendment No. 3 to the proposed rule change.\8\ The Commission
received no comments on the proposed rule change. This order grants
approval of the proposed rule change, as modified by Amendment Nos. 1,
2, and 3 thereto.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 76817 (January 4,
2016), 81 FR 978 (``Notice'').
\4\ In Amendment No. 1, the Exchange clarified the proposed rule
change by providing additional information regarding the currencies,
and instruments that provide exposure to such currencies, in which
each Fund will invest. Because Amendment No. 1 to the proposed rule
change does not materially alter the substance of the proposed rule
change or raise novel regulatory issues, Amendment No. 1 is not
subject to notice and comment (Amendment No. 1 is available at:
https:// www.sec.gov/comments/sr-nasdaq-2015-161/nasdaq2015161-1.pdf).
\5\ In Amendment No. 2, the Exchange expanded the application of
the Alternative Criteria (as discussed below) so that they will
apply on a continual basis. Because Amendment No. 2 does not
materially alter the substance of the proposed rule change or raise
novel regulatory issues, Amendment No. 2 is not subject to notice
and comment (Amendment No. 2 is available at: http: //www.sec.gov/comments/sr-nasdaq-2015-161/nasdaq2015161-2.pdf).
\6\ 15 U.S.C. 78s(b)(2).
\7\ See Securities Exchange Act Release No. 77192, 81 FR 9575
(February 25, 2016).
\8\ In Amendment No. 3 to the proposed rule change, the Exchange
clarified that: (a) All statements and representations made in the
proposal regarding the description of the portfolios, limitations on
portfolio holdings or reference assets, or the applicability of
Exchange rules and surveillance procedures shall constitute
continued listing requirements for listing the Shares on the
Exchange; (b) the issuer will advise the Exchange of any failure by
the Funds to comply with the continued listing requirements; (c)
pursuant to its obligations under Section 19(g)(1) of the Act, the
Exchange will monitor for compliance with the continued listing
requirements; and (d) if a Fund is not in compliance with the
applicable listing requirements, the Exchange will commence
delisting procedures under the Nasdaq 5800 Series. Because Amendment
No. 3 to the proposed rule change does not materially alter the
substance of the proposed rule change or raise unique or novel
regulatory issues, Amendment No. 3 is not subject to notice and
comment (Amendment No. 3 is available at: https://www.sec.gov/comments/sr-nasdaq-2015-161/nasdaq2015161-3.pdf).
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II. Exchange's Description of the Proposal
The Exchange proposes to list and trade the shares (``Shares'') of
the Europe Fund, Asia Pacific Fund, Emerging Markets Fund, and
Developed International Fund (individually, ``Fund,'' and collectively,
``Funds'') under Nasdaq Rule 5735, which governs the listing and
trading of Managed Fund Shares on the Exchange. Each Fund, which will
be a series of First Trust Exchange-Traded Fund III (``Trust''), will
be an actively managed exchange-traded fund (``ETF''). The Shares will
be offered by the Trust,\9\ which was established as a Massachusetts
business trust on January 9, 2008. The Trust is registered with the
Commission as an investment company and has filed a registration
statement on Form N-1A with the Commission.\10\
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\9\ According to the Exchange, the Trust has obtained certain
exemptive relief under the Investment Company Act of 1940 (``1940
Act''). See Investment Company Act Release No. 28468 (October 27,
2008) (File No. 812-13477).
\10\ See Post-Effective Amendment No. 29 to Registration
Statement on Form N-1A for the Trust, dated November 19, 2015 (File
Nos. 333-176976 and 811-22245) (``Registration Statement'').
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First Trust Advisors L.P. will be the investment adviser
(``Adviser'') to the
[[Page 21627]]
Funds. RiverFront Investment Group, LLC will serve as investment sub-
adviser (``Sub-Adviser'') to the Funds and provide day-to-day portfolio
management. First Trust Portfolios L.P. (``Distributor'') will be the
principal underwriter and distributor of each Fund's Shares. Brown
Brothers Harriman & Co. will act as the administrator, accounting
agent, custodian, and transfer agent to the Funds. According to the
Exchange, neither the Adviser nor the Sub-Adviser is a broker-dealer,
although the Adviser is affiliated with the Distributor, a broker-
dealer, and the Sub-Adviser is affiliated with Robert W. Baird & Co.
Incorporated, a broker-dealer. Each of the Adviser and Sub-Adviser has
implemented a fire wall with respect to its respective broker-dealer
affiliate regarding access to information concerning the composition or
changes to a portfolio.\11\
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\11\ In the event (a) the Adviser or the Sub-Adviser registers
as a broker-dealer, or becomes newly affiliated with a broker-
dealer, or (b) any new adviser or sub-adviser is a registered
broker-dealer or becomes affiliated with another broker-dealer, it
will implement a fire wall with respect to its relevant personnel
and/or such broker-dealer affiliate, as applicable, regarding access
to information concerning the composition of, and/or changes to, a
portfolio and will be subject to procedures designed to prevent the
use and dissemination of material, non-public information regarding
such portfolio.
---------------------------------------------------------------------------
The Exchange has made the following representations and statements
describing the Funds and the Funds' investment strategies, including
the Funds' portfolio holdings and investment restrictions.\12\
---------------------------------------------------------------------------
\12\ Additional information regarding the Funds, the Trust, and
the Shares, including investment strategies, risks, creation and
redemption procedures, fees, portfolio holdings disclosure policies,
calculation of net asset value (``NAV''), distributions, and taxes,
among other things, can be found in the Notice, the amendments, and
the Registration Statement, as applicable. See Notice, Amendment
Nos. 1-3, and Registration Statement, supra notes 3, 4, 5, 8, and
10, respectively.
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A. Exchange's Description of Principal Investment Strategies Applicable
to Each Fund
Each Fund's investment objective will be to provide capital
appreciation. Under normal market conditions,\13\ each Fund will seek
to achieve its investment objective by investing at least 80% of its
net assets (including investment borrowings) in a combination of: (i)
``Principal Fund Equity Securities'' (as defined below); (ii) forward
currency contracts and non-deliverable forward currency contracts
(collectively, ``Forward Contracts''); and (iii) currency transactions
on a spot (i.e., cash) basis.\14\
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\13\ The term ``under normal market conditions'' as used herein
includes, but is not limited to, the absence of adverse market,
economic, political or other conditions, including extreme
volatility or trading halts in the securities markets or the
financial markets generally; operational issues causing
dissemination of inaccurate market information; or force majeure
type events such as systems failure, natural or man-made disaster,
act of God, armed conflict, act of terrorism, riot or labor
disruption, or any similar intervening circumstance. On a temporary
basis, including for defensive purposes, during the initial invest-
up period and during periods of high cash inflows or outflows, a
Fund may depart from its principal investment strategies; for
example, it may hold a higher than normal proportion of its assets
in cash. During such periods, a Fund may not be able to achieve its
investment objective. A Fund may adopt a defensive strategy when the
Adviser and/or the Sub-Adviser believes securities in which such
Fund normally invests have elevated risks due to political or
economic factors and in other extraordinary circumstances.
\14\ A Fund would enter into Forward Contracts and/or currency
spot transactions for hedging purposes.
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For each Fund, (a) ``Principal Equity Securities'' will consist of
the following U.S. and non-U.S. exchange-listed securities: (i) Common
stocks; (ii) common and preferred shares of real estate investment
trusts (``REITs''); and (iii) American Depositary Receipts (``ADRs''),
European Depositary Receipts (``EDRs''), and Global Depositary Receipts
(``GDRs'' and, together with ADRs and EDRs, collectively, ``Depositary
Receipts''),\15\ and (b) ``Principal Fund Equity Securities'' will
consist of Principal Equity Securities that are suggested by such
Fund's name.\16\ Accordingly:
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\15\ The Funds will not invest in any unsponsored Depositary
Receipts.
\16\ With respect to Depositary Receipts, whether such Principal
Equity Securities are Principal Fund Equity Securities is based on
the underlying securities, the ownership of which is represented by
the Depositary Receipts (i.e., whether, as described below, the
relevant underlying security is a security of a European company, an
Asian Pacific company, an emerging market company, or a developed
market company, as applicable).
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(1) For the Europe Fund, Principal Fund Equity Securities will be
Principal Equity Securities of European companies; \17\
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\17\ European companies are those companies (i) whose securities
are traded principally on a stock exchange in a European country,
(ii) that are organized under the laws of or have a principal office
in a European country, or (iii) that have at least 50% of their
assets in, or derive at least 50% of their revenues or profits from,
a European country.
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(2) for the Asia Pacific Fund, Principal Fund Equity Securities
will be Principal Equity Securities of Asian Pacific companies; \18\
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\18\ Asian Pacific companies are those companies (i) whose
securities are traded principally on a stock exchange in an Asian
Pacific country, (ii) that are organized under the laws of or have a
principal office in an Asian Pacific country, or (iii) that have at
least 50% of their assets in, or derive at least 50% of their
revenues or profits from, an Asian Pacific country.
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(3) for the Emerging Markets Fund, Principal Fund Equity Securities
will be Principal Equity Securities of emerging market companies; \19\
and
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\19\ An emerging market company is one (i) domiciled or with a
principal place of business or primary securities trading market in
an emerging market country, or (ii) that derives a substantial
portion of its total revenues or profits from emerging market
countries.
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(4) for the Developed International Fund, Principal Fund Equity
Securities will be Principal Equity Securities of developed market
companies.\20\
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\20\ Developed market companies are those companies (i) whose
securities are traded principally on a stock exchange in a developed
market country, (ii) that are organized under the laws of or have a
principal office in a developed market country, or (iii) that have
at least 50% of their assets in, or derive at least 50% of their
revenues or profits from, a developed market country.
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In selecting securities for a Fund, the Sub-Adviser will score
individual securities from a portfolio of eligible securities according
to several core attributes, using multiple proprietary factors within
each core attribute. The Sub-Adviser will then rank each qualifying
security based on its core attribute score, and the highest scoring
securities will be considered for inclusion in the Fund's portfolio.
The Sub-Adviser will utilize its proprietary optimization process to
maximize the percentage of high-scoring securities included in each
Fund's portfolio.
In addition, for each Fund, by entering into Forward Contracts and
currency spot transactions, the Sub-Adviser will deploy a dynamic
currency hedge (hedging up to 100% of such Fund's foreign currency
exposure) based on its proprietary hedging methodology. The Sub-
Adviser's hedging methodology will be constructed from a combination of
quantitative measures and qualitative measures. Each Fund will only
enter into transactions in Forward Contracts with counterparties that
the Adviser and/or the Sub-Adviser reasonably believe are capable of
performing under the applicable Forward Contract.\21\
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\21\ According to the Exchange, each Fund will seek, where
possible, to use counterparties, as applicable, whose financial
status is such that the risk of default is reduced; however, the
risk of losses resulting from default is still possible. The Adviser
and/or the Sub-Adviser will evaluate the creditworthiness of
counterparties on an ongoing basis. In addition to information
provided by credit agencies, the Adviser's and/or Sub-Adviser's
analysis will evaluate each approved counterparty using various
methods of analysis and may consider the Adviser's and/or Sub-
Adviser's past experience with the counterparty, its known
disciplinary history, and its share of market participation.
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B. Exchange's Description of Other Investments for the Funds
According to the Exchange, each Fund may invest (in the aggregate)
up to 20% of its net assets in the following securities and
instruments.
[[Page 21628]]
Each Fund may invest in the following U.S. and non-U.S. exchange-
listed securities (other than Principal Fund Equity Securities): (i)
Common stocks; (ii) common and preferred shares of REITs; (iii)
Depositary Receipts; and (iv) equity securities of business development
companies (collectively, ``Other Equity Securities'').\22\
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\22\ For each Fund, Other Equity Securities and Principal Fund
Equity Securities are referred to collectively as ``Equity
Securities.''
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Each Fund may invest in short-term debt securities and other short-
term debt instruments (described below), as well as cash equivalents,
or it may hold cash. The percentage of each Fund invested in such
holdings or held in cash will vary and will depend on several factors,
including market conditions. Each Fund may invest in the following
short-term debt instruments: \23\ (1) Fixed rate and floating rate U.S.
government securities, including bills, notes, and bonds differing as
to maturity and rates of interest, which are either issued or
guaranteed by the U.S. Treasury or by U.S. government agencies or
instrumentalities; (2) certificates of deposit issued against funds
deposited in a bank or savings and loan association; (3) bankers'
acceptances, which are short-term credit instruments used to finance
commercial transactions; (4) repurchase agreements,\24\ which involve
purchases of debt securities; (5) bank time deposits, which are monies
kept on deposit with banks or savings and loan associations for a
stated period of time at a fixed rate of interest; (6) commercial
paper, which is short-term unsecured promissory notes; \25\ and (7)
short-term debt obligations issued or guaranteed by non-U.S.
governments or by their agencies or instrumentalities.
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\23\ The Exchange represents that short-term debt instruments
will be issued by issuers having a long-term debt rating of at least
A by Standard & Poor's Ratings Services (``S&P Ratings''), Moody's
Investors Service, Inc. (``Moody's''), or Fitch Ratings (``Fitch''),
and have a maturity of one year or less.
\24\ According to the Exchange, each Fund intends to enter into
repurchase agreements only with financial institutions and dealers
believed by the Adviser and/or the Sub-Adviser to present minimal
credit risks in accordance with criteria approved by the Board of
Trustees of the Trust. The Adviser and/or the Sub-Adviser will
review and monitor the creditworthiness of such institutions. The
Adviser and/or the Sub-Adviser will monitor the value of the
collateral at the time the transaction is entered into and at all
times during the term of the repurchase agreement. The Funds will
not enter into reverse repurchase agreements.
\25\ Each Fund may only invest in commercial paper rated A-1 or
higher by S&P Ratings, Prime-1 or higher by Moody's, or F1 or higher
by Fitch.
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Each Fund may invest (but only up to 5% of its net assets) in
exchange-listed equity index futures contracts.
C. Exchange's Description of the Funds' Equity Securities
According to the Exchange, under normal market conditions, each
Fund will invest in at least 20 Equity Securities. Each Fund will
satisfy the ``ISG Criteria'' (as described below) and/or the
``Alternative Criteria'' (as described below).
A Fund will satisfy the ISG Criteria if at least 90% of such Fund's
net assets that are invested (in the aggregate) in Equity Securities
will be invested in Equity Securities that trade in markets that are
members of the Intermarket Surveillance Group (``ISG'') \26\ or are
parties to a comprehensive surveillance sharing agreement with the
Exchange.
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\26\ For a list of the current members of ISG, see
www.isgportal.org. The Exchange notes that not all components of the
Disclosed Portfolio for a Fund may trade on markets that are members
of ISG or with which the Exchange has in place a comprehensive
surveillance sharing agreement.
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A Fund will satisfy the Alternative Criteria if, under normal
market conditions, its Equity Securities meet the following criteria at
the time of purchase and on a continuous basis: (1) Non-U.S. Equity
Securities \27\ each shall have a minimum market value of at least $100
million; (2) non-U.S. Equity Securities each shall have a minimum
global monthly trading volume of 250,000 shares, or minimum global
notional volume traded per month of $25,000,000, averaged over the last
six months; (3) the most heavily weighted non-U.S. Equity Security
shall not exceed 25% of the weight of the Fund's entire portfolio and,
to the extent applicable, the five most heavily weighted non-U.S.
Equity Securities shall not exceed 60% of the weight of the Fund's
entire portfolio; (4) each non-U.S. Equity Security shall be listed and
traded on an exchange that has last-sale reporting; and (5) all of such
Fund's net assets that are invested (in the aggregate) in Equity
Securities other than non-U.S. Equity Securities shall be invested in
Equity Securities that trade in markets that are members of ISG or are
parties to a comprehensive surveillance sharing agreement with the
Exchange.
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\27\ For purposes of this filing, the term ``non-U.S. Equity
Securities'' means Equity Securities that are not listed on a U.S.
exchange.
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D. Exchange's Description of the Funds' Transactions in Forward
Contracts and Exchange-Listed Equity Index Futures Contracts
According to the Exchange, each Fund's transactions in Forward
Contracts and exchange-listed equity index futures contracts will be
consistent with its investment objective and the 1940 Act and will not
be used to seek to achieve a multiple or inverse multiple of an index.
Each Fund will comply with the regulatory requirements of the
Commission with respect to coverage in connection with its transactions
in Forward Contracts and exchange-listed equity index futures
contracts. If the applicable guidelines prescribed under the 1940 Act
so require, a Fund will earmark cash, U.S. government securities and/or
other liquid assets permitted by the Commission in the amount
prescribed.
E. Exchange's Description of the Funds' Investment Restrictions
Each Fund may hold up to an aggregate amount of 15% of its net
assets in illiquid assets (calculated at the time of investment),
deemed illiquid by the Adviser and/or the Sub-Adviser.\28\ Each Fund
will monitor its portfolio liquidity on an ongoing basis to determine
whether, in light of current circumstances, an adequate level of
liquidity is being maintained, and will consider taking appropriate
steps in order to maintain adequate liquidity if, through a change in
values, net assets, or other circumstances, more than 15% of such
Fund's net assets are held in illiquid assets. Illiquid assets include
securities subject to contractual or other restrictions on resale and
other instruments that lack readily available markets as determined in
accordance with Commission staff guidance.
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\28\ According to the Exchange, in determining the liquidity of
the Funds' investments, the Adviser and/or the Sub-Adviser may
consider the following factors: (i) The frequency of trades and
quotes for the security or other instrument; (ii) the number of
dealers wishing to purchase or sell the security or other instrument
and the number of other potential purchasers; (iii) dealer
undertakings to make a market in the security or other instrument;
and (iv) the nature of the security or other instrument and the
nature of the marketplace in which it trades (e.g., the time needed
to dispose of the security or other instrument, the method of
soliciting offers and the mechanics of transfer).
---------------------------------------------------------------------------
The Funds may not invest 25% or more of the value of their
respective total assets in securities of issuers in any one industry.
This restriction does not apply to (a) obligations issued or guaranteed
by the U.S. government, its agencies or instrumentalities, or (b)
securities of other investment companies.
Each Fund intends to qualify each year as a regulated investment
company under Subchapter M of the Internal Revenue Code.
III. Discussion and Commission Findings
After careful review, the Commission finds that the Exchange's
proposal is consistent with the Exchange Act and the rules and
regulations thereunder
[[Page 21629]]
applicable to a national securities exchange.\29\ In particular, the
Commission finds that the proposed rule change, as modified by
Amendment Nos. 1, 2, and 3 thereto, is consistent with Section 6(b)(5)
of the Exchange Act,\30\ which requires, among other things, that the
Exchange's rules be designed to promote just and equitable principles
of trade, to remove impediments to and perfect the mechanism of a free
and open market and a national market system, and, in general, to
protect investors and the public interest.
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\29\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
\30\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------
The Commission also finds that the proposal is consistent with
Section 11A(a)(1)(C)(iii) of the Exchange Act,\31\ which sets forth
Congress's finding that it is in the public interest and appropriate
for the protection of investors and the maintenance of fair and orderly
markets to assure the availability to brokers, dealers, and investors
of information with respect to quotations for, and transactions in,
securities.
---------------------------------------------------------------------------
\31\ 15 U.S.C. 78k-1(a)(1)(C)(iii).
---------------------------------------------------------------------------
Quotation and last-sale information for the Shares will be
available via Nasdaq proprietary quote and trade services, as well as
in accordance with the Unlisted Trading Privileges and the Consolidated
Tape Association (``CTA'') plans for the Shares. On each business day,
before commencement of trading in Shares in the Regular Market Session
\32\ on the Exchange, each Fund will disclose on its Web site the
Disclosed Portfolio held by such Fund that will form the basis for such
Fund's calculation of NAV at the end of the business day.\33\ The NAV
of each Fund's Shares generally will be calculated once daily Monday
through Friday as of the close of regular trading on the New York Stock
Exchange, generally 4:00 p.m., Eastern Time.\34\
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\32\ See Nasdaq Rule 4120(b)(4) (describing the three trading
sessions on the Exchange: (1) Pre-Market Session from 4:00 a.m. to
9:30 a.m., Eastern Time; (2) Regular Market Session from 9:30 a.m.
to 4:00 p.m. or 4:15 p.m., Eastern Time; and (3) Post-Market Session
from 4:00 p.m. or 4:15 p.m. to 8:00 p.m., Eastern Time).
\33\ Nasdaq Rule 5735(c)(2) defines the term ``Disclosed
Portfolio.'' According to the Exchange, each Fund's disclosure of
derivative positions in the Disclosed Portfolio will include
sufficient information for market participants to use to value these
positions intraday. On a daily basis, each Fund will also disclose
on its Web site the following information regarding each portfolio
holding, as applicable to the type of holding: ticker symbol, CUSIP
number or other identifier, if any; a description of the holding
(including the type of holding); the identity of the security,
index, or other asset or instrument underlying the holding, if any;
quantity held (as measured by, for example, par value, notional
value, or number of shares, contracts, or units); maturity date, if
any; coupon rate, if any; effective date, if any; market value of
the holding; and percentage weighting of the holding in the Fund's
portfolio. The Web site information will be publicly available at no
charge.
\34\ According to the Exchange, the Funds' investments will be
valued daily. The following investments will typically be valued
using information provided by a third-party pricing service
(``Pricing Service''): (a) Except as provided below, short term U.S.
government securities, commercial paper, bankers' acceptances, and
short-term debt obligations issued or guaranteed by non-U.S.
governments or by their agencies or instrumentalities (collectively,
``Short Term Debt Instruments''); and (b) currency spot
transactions. Debt instruments may be valued at evaluated mean
prices, as provided by Pricing Services. Short Term Debt Instruments
having a remaining maturity of 60 days or less when purchased will
typically be valued at cost adjusted for amortization of premiums
and accretion of discounts, provided the pricing committee of the
Adviser (``Pricing Committee'') has determined that the use of
amortized cost is an appropriate reflection of value given market
and issuer specific conditions existing at the time of the
determination. Overnight repurchase agreements will be valued at
amortized cost when it represents the best estimate of value. Term
repurchase agreements (i.e., those whose maturity exceeds seven
days) will be valued at the average of the bid quotations obtained
daily from at least two recognized dealers. Certificates of deposit
and bank time deposits will typically be valued at cost. Equity
Securities that are listed on any exchange other than the Exchange
and the London Stock Exchange Alternative Investment Market
(``AIM'') will typically be valued at the last-sale price on the
exchange on which they are principally traded on the business day as
of which such value is being determined. Equity Securities listed on
the Exchange or the AIM will typically be valued at the official
closing price on the business day as of which such value is being
determined. If there has been no sale on such day, or no official
closing price in the case of securities traded on the Exchange or
the AIM, such securities will typically be valued using fair value
pricing. Equity Securities traded on more than one securities
exchange will be valued at the last sale price or official closing
price, as applicable, on the business day as of which such value is
being determined at the close of the exchange representing the
principal market for such securities. Exchange-listed equity index
futures contracts will typically be valued at the closing price in
the market where such instruments are principally traded. Forward
Contracts will typically be valued at the current day's interpolated
foreign exchange rate, as calculated using the current day's spot
rate, and the thirty, sixty, ninety, and one-hundred-eighty day
forward rates provided by a Pricing Service or by certain
independent dealers in such contracts. Assets denominated in foreign
currencies will be translated into U.S. dollars at the exchange rate
of such currencies against the U.S. dollar as provided by a Pricing
Service. The value of assets denominated in foreign currencies will
be converted into U.S. dollars at the exchange rates in effect at
the time of valuation.
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In addition, the Intraday Indicative Value \35\ for each Fund,
available on the NASDAQ OMX Information LLC proprietary index data
service, will be based upon the current value for the components of the
Disclosed Portfolio and will be updated and widely disseminated by one
or more major market data vendors and broadly displayed at least every
15 seconds during the Regular Market Session. The Intraday Indicative
Value will be based on quotes and closing prices from the securities'
local market and may not reflect events that occur subsequent to the
local market's close.
---------------------------------------------------------------------------
\35\ Nasdaq Rule 5735(c)(3) defines the term ``Intraday
Indicative Value.''
---------------------------------------------------------------------------
Information regarding market price and trading volume of the Shares
will be continually available on a real-time basis throughout the day
on brokers' computer screens and other electronic services. Information
regarding the previous day's closing price and trading volume
information for the Shares will be published daily in the financial
section of newspapers. Quotation and last-sale information for the
Equity Securities (to the extent traded on a U.S. exchange) will be
available from the exchanges on which they are traded as well as in
accordance with any applicable CTA plans. Pricing information for
Short-Term Debt Instruments, repurchase agreements, Forward Contracts,
bank time deposits, certificates of deposit, and currency spot
transactions will be available from major broker-dealer firms and/or
major market data vendors and/or Pricing Services. Pricing information
for exchange-listed equity index futures contracts and non-U.S. Equity
Securities will be available from the applicable listing exchange and
from major market data vendors. In addition, the Exchange notes that
the Funds' Web site will include a form of the prospectus for the Funds
and additional data relating to NAV and other applicable quantitative
information.
The Commission also believes that the proposal to list and trade
the Shares is reasonably designed to promote fair disclosure of
information that may be necessary to price the Shares appropriately and
to prevent trading when a reasonable degree of transparency cannot be
assured. The Exchange states that it will obtain a representation from
the issuer of the Shares that the NAV per Share will be calculated
daily and that the NAV and the Disclosed Portfolio will be made
available to all market participants at the same time. The Exchange
also represents that it may consider all relevant factors in exercising
its discretion to halt or suspend trading in the Shares of a Fund. The
Exchange will halt trading in the Shares under the conditions specified
in Nasdaq Rules 4120 and 4121, including the trading pauses under
Nasdaq Rules 4120(a)(11) and (12). Trading may be halted because of
market conditions or for reasons that, in the view of the Exchange,
make
[[Page 21630]]
trading in the Shares inadvisable.\36\ Trading in the Shares also will
be subject to Rule 5735(d)(2)(D), which sets forth circumstances under
which Shares of a Fund may be halted.
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\36\ These may include: (1) The extent to which trading is not
occurring in the securities and/or the other assets constituting the
Disclosed Portfolio of a Fund; or (2) whether other unusual
conditions or circumstances detrimental to the maintenance of a fair
and orderly market are present.
---------------------------------------------------------------------------
The Exchange states that it has a general policy prohibiting the
distribution of material, non-public information by its employees. The
Exchange further states that neither the Adviser nor the Sub-Adviser is
a broker-dealer, but each is affiliated with a broker-dealer, and that
the Adviser and Sub-Adviser has each implemented a fire wall with
respect to its respective broker-dealer affiliate regarding access to
information concerning the composition of, and changes to, each Fund's
portfolio.\37\ Further, the Commission notes that the Reporting
Authority \38\ that provides the Disclosed Portfolio must implement and
maintain, or be subject to, procedures designed to prevent the use and
dissemination of material, non-public information regarding the actual
components of the portfolio.\39\ The Exchange represents that trading
in the Shares will be subject to the existing trading surveillances,
administered by both Nasdaq and also the Financial Industry Regulatory
Authority (``FINRA'') on behalf of the Exchange, which are designed to
detect violations of Exchange rules and applicable federal securities
laws.\40\
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\37\ See supra note 11 and accompanying text. The Exchange
further represents that an investment adviser to an open-end fund is
required to be registered under the Investment Advisers Act of 1940
(``Advisers Act''). As a result, the Adviser, the Sub-Adviser, and
their related personnel are subject to the provisions of Rule 204A-1
under the Advisers Act relating to codes of ethics. This Rule
requires investment advisers to adopt a code of ethics that reflects
the fiduciary nature of the relationship to clients as well as
compliance with other applicable securities laws. Accordingly,
procedures designed to prevent the communication and misuse of non-
public information by an investment adviser must be consistent with
Rule 204A-1 under the Advisers Act. In addition, Rule 206(4)-7 under
the Advisers Act makes it unlawful for an investment adviser to
provide investment advice to clients unless such investment adviser
has (i) adopted and implemented written policies and procedures
reasonably designed to prevent violation, by the investment adviser
and its supervised persons, of the Advisers Act and the Commission
rules adopted thereunder; (ii) implemented, at a minimum, an annual
review regarding the adequacy of the policies and procedures
established pursuant to subparagraph (i) above and the effectiveness
of their implementation; and (iii) designated an individual (who is
a supervised person) responsible for administering the policies and
procedures adopted under subparagraph (i) above.
\38\ Nasdaq Rule 5735(c)(4) defines ``Reporting Authority.''
\39\ See Nasdaq Rule 5735(d)(2)(B)(ii).
\40\ The Exchange represents that FINRA surveils trading on the
Exchange pursuant to a regulatory services agreement and that the
Exchange is responsible for FINRA's performance under this
regulatory services agreement.
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Nasdaq deems the Shares to be equity securities, thus rendering
trading in the Shares subject to Nasdaq's existing rules governing the
trading of equity securities. In support of this proposal, the Exchange
represented that:
(1) The Shares will be subject to Nasdaq Rule 5735, which sets
forth the initial and continued listing criteria applicable to Managed
Fund Shares.
(2) Trading in the Shares will be subject to the existing trading
surveillances, administered by both Nasdaq and FINRA on behalf of the
Exchange, which are designed to detect violations of Exchange rules and
applicable federal securities laws. The Exchange represents that these
procedures are adequate to properly monitor Exchange trading of the
Shares in all trading sessions and to deter and detect violations of
Exchange rules and applicable federal securities laws.
(3) FINRA, on behalf of the Exchange, will communicate as needed
regarding trading in the Shares and certain of the Equity Securities
and exchange-listed equity index futures contracts held by the Funds
with other markets and other entities that are members of ISG, and
FINRA may obtain trading information regarding trading in the Shares
and such securities and instruments held by the Funds from such markets
and other entities. In addition, the Exchange may obtain information
regarding trading in the Shares and certain of the Equity Securities
and exchange-listed equity index futures contracts held by the Funds
from markets and other entities that are members of ISG, which includes
securities and futures exchanges, or with which the Exchange has in
place a comprehensive surveillance sharing agreement. Moreover, FINRA,
on behalf of the Exchange, will be able to access, as needed, trade
information for certain fixed income securities held by the Funds
reported to FINRA's Trade Reporting and Compliance Engine (``TRACE'').
(4) For each Fund, at least 90% of such Fund's net assets that are
invested (in the aggregate) in exchange-listed equity index futures
contracts will be invested in instruments that trade in markets that
are members of ISG or are parties to a comprehensive surveillance
sharing agreement with the Exchange.
(5) The Exchange has appropriate rules to facilitate transactions
in the Shares during all trading sessions.
(6) Prior to the commencement of trading, the Exchange will inform
its members in an Information Circular of the special characteristics
and risks associated with trading the Shares. Specifically, the
Information Circular for each Fund will discuss the following: (a) The
procedures for purchases and redemptions of Shares in Creation Units
(and that Shares are not individually redeemable); (b) Nasdaq Rule
2111A, which imposes suitability obligations on Nasdaq members with
respect to recommending transactions in the Shares to customers; (c)
how information regarding the Intraday Indicative Value and the
Disclosed Portfolio is disseminated; (d) the risks involved in trading
the Shares during the Pre-Market and Post-Market Sessions when an
updated Intraday Indicative Value will not be calculated or publicly
disseminated; (e) the requirement that members deliver a prospectus to
investors purchasing newly issued Shares prior to or concurrently with
the confirmation of a transaction; and (f) trading information.
(7) For initial and continued listing, the Funds must be in
compliance with Rule 10A-3 under the Act.\41\
---------------------------------------------------------------------------
\41\ See 17 CFR 240.10A-3.
---------------------------------------------------------------------------
(8) Each Fund may hold up to an aggregate amount of 15% of its net
assets in illiquid assets.
(9) The Pricing Committee will be subject to procedures designed to
prevent the use and dissemination of material non-public information
regarding each Fund's portfolio.
(10) Each Fund will satisfy: (a) The ISG Criteria; and/or (b) the
Alternative Criteria at the time of purchase and on a continuous basis.
(11) A minimum of 100,000 Shares will be outstanding at the
commencement of trading on the Exchange.
The Exchange represents that all statements and representations
made in the filing regarding (a) the description of the portfolios, (b)
limitations on portfolio holdings or reference assets, or (c) the
applicability of Exchange rules and surveillance procedures shall
constitute continued listing requirements for listing the Shares on the
Exchange. In addition, the issuer has represented to the Exchange that
it will advise the Exchange of any failure by the Funds to comply with
the continued listing requirements, and, pursuant to its obligations
under Section 19(g)(1) of the Act, the Exchange will monitor for
compliance with the continued listing requirements.\42\ If a Fund is
not in
[[Page 21631]]
compliance with the applicable listing requirements, the Exchange will
commence delisting procedures under the Nasdaq 5800 Series. This
approval order is based on all of the Exchange's representations,
including those set forth above, in the Notice, and in Amendment Nos.
1, 2, and 3 to the proposed rule change. The Commission notes that the
Funds and the Shares must comply with the requirements of Nasdaq Rule
5735, including those set forth in this proposed rule change, as
modified by Amendment Nos. 1, 2, and 3 thereto, to be listed and traded
on the Exchange on an initial and continuing basis.
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\42\ The Commission notes that certain other proposals for the
listing and trading of Managed Fund Shares include a representation
that the exchange will ``surveil'' for compliance with the continued
listing requirements. See, e.g., Amendment No. 2 to SR-BATS-2016-04,
available at: https://www.sec.gov/comments/sr-bats-2016-04/bats201604-2.pdf. In the context of this representation, it is the
Commission's view that ``monitor'' and ``surveil'' both mean ongoing
oversight of the Fund's compliance with the continued listing
requirements. Therefore, the Commission does not view ``monitor'' as
a more or less stringent obligation than ``surveil'' with respect to
the continued listing requirements.
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For the foregoing reasons, the Commission finds that the proposed
rule change, as modified by Amendment Nos. 1, 2, and 3 thereto, is
consistent with Section 6(b)(5) of the Act \43\ and the rules and
regulations thereunder applicable to a national securities exchange.
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\43\ 15 U.S.C. 78f(b)(5).
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IV. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\44\ that the proposed rule change (SR-NASDAQ-2015-161),
as modified by Amendment Nos. 1, 2, and 3 thereto, be, and it hereby
is, approved.
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\44\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\45\
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\45\ 17 CFR 200.30-3(a)(12).
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Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016-08307 Filed 4-11-16; 8:45 am]
BILLING CODE 8011-01-P