Self-Regulatory Organizations; Cboe BZX Exchange, Inc.; Order Granting Approval of a Proposed Rule Change, as Modified by Amendment No. 1, To List and Trade Shares of the JPMorgan Inflation Managed Bond ETF of the J.P. Morgan Exchange-Traded Fund Trust Under Rule 14.11(i), Managed Fund Shares, 6026-6031 [2019-03175]
Download as PDF
6026
Federal Register / Vol. 84, No. 37 / Monday, February 25, 2019 / Notices
POLICIES AND PRACTICES FOR STORAGE OF
RECORDS:
ADMINISTRATIVE, TECHNICAL, AND PHYSICAL
SAFEGUARDS:
Automated database, computer
storage media, digital files, and paper
files.
Paper records, computers, and
computer storage media are located in
controlled-access areas under
supervision of program personnel.
Access to these areas is limited to
authorized personnel, who must be
identified with a badge. Access to
records is limited to individuals whose
official duties require such access.
Contractors and licensees are subject to
contract controls and unannounced onsite audits and inspections. Computers
are protected by mechanical locks, card
key systems, or other physical access
control methods. The use of computer
systems is regulated with installed
security software, computer logon
identifications, and operating system
controls including access controls,
terminal and transaction logging, and
file management software.
POLICIES AND PRACTICES FOR RETRIEVAL OF
RECORDS:
By employee name, Social Security
Number, Employee Identification
Number, occupation code, occupation
title, or duty or pay location.
amozie on DSK3GDR082PROD with NOTICES1
POLICIES AND PRACTICES FOR RETENTION AND
DISPOSAL OF RECORDS:
1. Leave application and
unauthorized overtime records are
retained 3 years. Time and attendance
records (other than payroll) and local
payroll records are retained 3 years.
Automated payroll records are retained
10 years.
2. Uniform allowance case files are
retained 3 years; and automated records
are retained 6 years.
3. Records of monetary awards with a
status that they have been processed,
processing failed, cancelled, and
reported (Service Award Pins,
Retirement Service Awards,
Posthumous Service Awards) are
retained 7 years, as payroll records
would have been affected/processed.
Records of award submissions with the
status approved, deleted, and/or draft
are retained 31 days, as payroll records
would not have been affected/
processed.
4. Records of employee submitted
ideas are maintained for 90 days after
being closed.
5. Injury compensation records are
retained 5 years. Records resulting in
affirmative identifications become part
of a research case file, which if research
determines applicability, become either
part of an investigative case record or a
remuneration case record that is
retained 2 years beyond the
determination.
6. Monetary claims records are
retained 3 years.
7. Automated records of garnishment
cases are retained 6 months. Records
located at a Post Office are retained 3
years.
8. Overtime administrative records are
retained for 7 years.
9. Tax preparation records are limited
to an employee’s previous year’s wages,
tax documentation and health insurance
coverage as required by the Affordable
Care Act
Records existing on paper are
destroyed by burning, pulping, or
shredding. Records existing on
computer storage media are destroyed
according to the applicable USPS media
sanitization practice.
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RECORD ACCESS PROCEDURES:
Requests for access must be made in
accordance with the Notification
Procedure above and USPS Privacy Act
regulations regarding access to records
and verification of identity under 39
CFR 266.6.
CONTESTING RECORD PROCEDURES:
See Notification Procedures below
and Record Access Procedures above.
NOTIFICATION PROCEDURES:
Individuals wanting to know if
information about them is maintained in
this system must address inquiries to
the facility head where currently or last
employed. Headquarters employees
must submit inquiries to Corporate
Personnel Management, 475 L’Enfant
Plaza SW, Washington, DC 20260.
Inquiries must include full name, Social
Security Number or Employee
Identification Number, name and
address of facility where last employed,
and dates of USPS employment.
HISTORY:
February 23, 2017, 82 FR 11489;
March 2, 2015, 80 FR 11241; June 17,
2011, 76 FR 35483; April 29, 2005, 70
FR 22516.
*
*
*
*
*
Brittany M. Johnson,
Attorney, Federal Compliance.
[FR Doc. 2019–03183 Filed 2–22–19; 8:45 am]
BILLING CODE 7710–12–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–85166; File No. SR–
CboeBZX–2018–077]
Self-Regulatory Organizations; Cboe
BZX Exchange, Inc.; Order Granting
Approval of a Proposed Rule Change,
as Modified by Amendment No. 1, To
List and Trade Shares of the JPMorgan
Inflation Managed Bond ETF of the J.P.
Morgan Exchange-Traded Fund Trust
Under Rule 14.11(i), Managed Fund
Shares
February 19, 2019.
I. Introduction
On November 2, 2018, Cboe BZX
Exchange, Inc. (‘‘Exchange’’ or ‘‘BZX’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to list and trade shares
(‘‘Shares’’) of the JPMorgan Inflation
Managed Bond ETF (‘‘Fund’’) of the J.P.
Morgan Exchange-Traded Fund Trust
(‘‘Trust’’) under Rule 14.11(i)
(‘‘Managed Fund Shares’’).
The proposed rule change was
published for comment in the Federal
Register on November 21, 2018.3 On
December 10, 2018, the Exchange filed
Amendment No. 1 to the proposed rule
change.4 On December 21, 2018, the
1 15
EXEMPTIONS PROMULGATED FOR THE SYSTEM:
Records in this system relating to
injury compensation that have been
compiled in reasonable anticipation of a
civil action or proceeding are exempt
from individual access as permitted by
5 U.S.C. 552a(d)(5). The USPS has also
claimed exemption from certain
provisions of the Act for several of its
other systems of records at 39 CFR
266.9. To the extent that copies of
exempted records from those other
systems are incorporated into this
system, the exemptions applicable to
the original primary system continue to
apply to the incorporated records.
PO 00000
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Fmt 4703
Sfmt 4703
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 84604
(November 15, 2018), 83 FR 58789 (‘‘Notice’’).
4 In Amendment No. 1, which amended and
replaced the proposed rule change in its entirety,
the Exchange: (a) Amended the universe of Equity
Holdings (as defined herein); (b) stated where
intraday price quotations for Bonds (as defined
herein) and Equity Holdings that are not exchangetraded could be found; (c) represented that the
Equity Holdings held by the Fund that will trade
on markets that are a member of Intermarket
Surveillance Group (‘‘ISG’’) or affiliated with a
member of ISG or with which the Exchange has in
place a comprehensive surveillance sharing
agreement would be the exchange-listed Equity
Holdings; and (d) made technical and conforming
changes. Because Amendment No. 1 does not
materially alter the substance of the proposed rule
change or raise unique or novel regulatory issues
2 17
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Federal Register / Vol. 84, No. 37 / Monday, February 25, 2019 / Notices
Commission extended the time 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.5 The Commission
has received no comments on the
proposal, as modified by Amendment
No. 1. This order grants approval of the
proposed rule change, as modified by
Amendment No. 1.
II. Exchange’s Description of the
Proposed Rule Change, as Modified by
Amendment No. 1
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The Exchange proposes to list and
trade the Shares of the Fund pursuant
to BZX Rule 14.11(i), which governs the
listing and trading of Managed Fund
Shares on the Exchange. The Shares will
be offered by the Trust, which was
established as a Delaware statutory
trust.6 The Fund will be an actively
managed exchange-traded fund. J.P
Morgan Investment Management, Inc. is
the investment adviser (‘‘Adviser’’) and
the administrator to the Fund. JPMorgan
Chase Bank, N.A. is the custodian and
transfer agent for the Trust. JPMorgan
Distribution Services, Inc. serves as the
distributor for the Trust. The Exchange
represents the Adviser is not a brokerdealer, but is affiliated with multiple
broker-dealers and has implemented
and will maintain ‘‘fire walls’’ with
respect to such broker-dealers regarding
access to information concerning the
composition of, and/or changes to, the
Fund’s portfolio. In addition, Adviser
personnel who make decisions
regarding the Fund’s portfolio are
subject to procedures designed to
prevent the use and dissemination of
material, non-public information
regarding the Fund’s portfolio.7
under the Act, Amendment No. 1 is not subject to
notice and comment. Amendment No. 1 to the
proposed rule change is available at: https://
www.sec.gov/comments/SR-cboebzx-2018-077/
srcboebzx2018077-4777675-176818.pdf.
5 See Securities Exchange Act Release No. 84944,
83 FR 67751 (December 31, 2018).
6 The Exchange represents that the Trust is
registered under the Investment Company Act of
1940 (‘‘1940 Act’’). See Registration Statement on
Form N–1A for the Trust, dated July 31, 2018 (File
Nos. 333–191837 and 811–22903) (‘‘Registration
Statement’’). The Exchange further represents that
the Trust has obtained certain exemptive relief
under the 1940 Act.
7 See BZX Rule 14.11(i)(7). The Exchange further
represents that, in the event that (a) the Adviser
becomes registered as a broker-dealer or newly
affiliated with another broker-dealer, or (b) any new
adviser or sub–adviser is a registered broker-dealer
or becomes affiliated with a broker-dealer, it will
implement and maintain a fire wall with respect to
its relevant personnel or such broker-dealer
affiliate, as applicable, regarding access to
information concerning the composition of, and/or
changes to, the portfolio, and will be subject to
procedures designed to prevent the use and
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Under the proposal, the Exchange
seeks to permit the Fund to hold
Inflation Swaps and Other Derivatives,
each as defined below, in a manner that
may not comply with BZX Rules
14.11(i)(4)(C)(iv)(a),8
14.11(i)(4)(C)(iv)(b),9 and/or
14.11(i)(4)(C)(v),10 as further described
below.11 Otherwise, the Exchange
dissemination of material, non-public information
regarding such portfolio.
8 BZX Rule 14.11(i)(4)(C)(iv)(a) provides that
‘‘there shall be no limitation to the percentage of the
portfolio invested in such holdings; provided,
however, that in the aggregate, at least 90% of the
weight of such holdings invested in futures,
exchange-traded options, and listed swaps shall, on
both an initial and continuing basis, consist of
futures, options, and swaps for which the Exchange
may obtain information via the ISG from other
members or affiliates of the ISG or for which the
principal market is a market with which the
Exchange has a comprehensive surveillance sharing
agreement, calculated using the aggregate gross
notional value of such holdings.’’ The Exchange is
proposing that the Fund be exempt from this
requirement only as it relates to the Fund’s holdings
in certain credit default swaps, interest rate swaps,
and Inflation Swaps, as further described below.
9 BZX Rule 14.11(i)(4)(C)(iv)(b) provides that ‘‘the
aggregate gross notional value of listed derivatives
based on any five or fewer underlying reference
assets shall not exceed 65% of the weight of the
portfolio (including gross notional exposures), and
the aggregate gross notional value of listed
derivatives based on any single underlying
reference asset shall not exceed 30% of the weight
of the portfolio (including gross notional
exposures).’’ The Exchange is proposing that the
Fund would meet neither the 65% nor the 30%
requirements of BZX Rule 14.11(i)(4)(C)(iv)(b).
Specifically, the Exchange is proposing that the
Fund be exempt from this requirement as it relates
to the Fund’s holdings in listed derivatives, which
include U.S. Treasury futures, Eurodollar futures,
options on U.S. Treasuries and Treasury futures,
credit default swaps, and certain Inflation Swaps
and interest rate swaps, as further described below,
which could constitute as much as 100% of the
weight of the portfolio (including gross notional
exposures) based on a single underlying reference
asset.
10 BZX Rule 14.11(i)(4)(C)(v) provides that ‘‘the
portfolio may, on both an initial and continuing
basis, hold OTC derivatives, including forwards,
options, and swaps on commodities, currencies and
financial instruments (e.g., stocks, fixed income,
interest rates, and volatility) or a basket or index of
any of the foregoing, however the aggregate gross
notional value of OTC derivatives shall not exceed
20% of the weight of the portfolio (including gross
notional exposures).’’ The Exchange is proposing
that the Fund be exempt from this requirement as
it relates to the Fund’s holdings in OTC derivatives,
which could constitute as much as 75% of the
weight of the portfolio (including gross notional
exposures).
11 The Adviser notes that the Fund may by virtue
of its holdings be issued certain exchange-listed or
OTC equity instruments, including common and
preferred stock, common stock warrants and rights,
and securities issued by real estate investment
trusts (collectively, ‘‘Equity Holdings’’), that may
not meet the requirements of Rule 14.11(i)(4)(C)(i).
The Fund will not purchase such instruments and
will dispose of such holdings as the Adviser
determines is in the best interest of the Fund’s
shareholders. Equity Holdings will not constitute
more than 10% of the Fund’s net assets. The
Adviser expects that the Fund will generally
acquire Equity Holdings through issuances that it
receives by virtue of its other holdings, such as
corporate actions or convertible securities.
PO 00000
Frm 00049
Fmt 4703
Sfmt 4703
6027
represents that the Fund will comply
with all other listing requirements on an
initial and continued listing basis under
BZX Rule 14.11(i).
A. Exchange’s Description of the Fund’s
Primary Investments 12
According to the Exchange, the Fund
is designed to protect the total return 13
generated by its fixed income holdings
from inflation risk and will seek to
maximize inflation protected total
return. The Fund seeks to achieve its
investment objective by investing, under
Normal Market Conditions,14 at least
80% of its net assets in Bonds,15
Inflation Hedging Instruments, and
Other Derivatives, as defined below.
The Fund will gain exposure to U.S.
dollar-denominated bonds primarily
through investing directly in Bonds. Up
to 10% of the Fund’s total assets may be
invested in securities rated below
investment grade (junk bonds). Junk
bonds are rated in the fifth or lower
rated categories (for example, BB+ or
12 The Commission notes that additional
information regarding the Fund, 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 Amendment No. 1 to
the proposed rule change and the Registration
Statement, as applicable. See Amendment No. 1
and Registration Statement, supra notes 4 and 6,
respectively.
13 According to the Exchange, total return
includes income and capital appreciation.
14 As defined in BZX Rule 14.11(i)(3)(E), the term
‘‘Normal Market Conditions’’ includes, but is not
limited to, the absence of trading halts in the
applicable financial markets generally; operational
issues causing dissemination of inaccurate market
information or system failures; or force majeure
type events such as natural or man-made disaster,
act of God, armed conflict, act of terrorism, riot or
labor disruption, or any similar intervening
circumstance.
15 For purposes of this proposal, the term ‘‘Bond’’
includes only the following U.S. dollar
denominated instruments issued by the U.S.
Government or its agencies and instrumentalities, a
domestic or a foreign corporation or a municipality:
Corporate bonds, U.S. government and agency debt
securities (excluding Treasury Inflation Protected
Securities (‘‘TIPS’’), which, as described below,
may be held by the Fund in order to attempt to
mitigate inflation risk), asset-backed securities, and
mortgage-related and mortgage-backed securities.
Mortgage-related and mortgage-backed securities
may be structured as collateralized mortgage
obligations (agency and non-agency), stripped
mortgage-backed securities (interest-only or
principal-only), commercial mortgage-backed
securities, mortgage pass-through securities,
collateralized mortgage obligations, adjustable rate
mortgages, convertible bonds, and zero-coupon
obligations. The Exchange notes that the Fund’s
holdings in Bonds will meet the requirements of
BZX Rule 14.11(i)(4)(C)(ii)(a)–(e) related to the fixed
income securities portion of the Fund, including
the requirement that non-agency, non-GSE, and
privately-issued mortgage-related and other assetbacked securities components of a portfolio shall
not account, in the aggregate, for more than 20%
of the weight of the fixed income portion of the
portfolio.
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lower by Standard & Poor’s Ratings
Services and Ba1 or lower by Moody’s).
The Fund may also use the following
instruments to gain exposure to credit or
interest rates: Credit default swaps,16
interest rate swaps,17 Eurodollar futures,
U.S. Treasury futures, options on U.S.
Treasury Futures, and options on U.S.
Treasuries 18 (collectively, ‘‘Other
Derivatives’’).
The Fund will attempt to mitigate the
inflation risk of the Fund’s exposure to
Bonds primarily through the use of
either over-the-counter (‘‘OTC’’) or
listed inflation swaps (‘‘Inflation
Swaps’’),19 which are managed on an
active basis. Additionally, the Fund may
also attempt to mitigate inflation risk
through investing in TIPS (together with
Inflation Swaps, collectively, ‘‘Inflation
Hedging Instruments’’). The Exchange is
proposing to allow the Fund to hold up
to 100% of the weight of its portfolio
(including gross notional exposure) in
Inflation Swaps and Other Derivatives,
collectively, in a manner that may not
comply with BZX Rules
14.11(i)(4)(C)(iv)(a),20
14.11(i)(4)(C)(iv)(b),21 and/or
14.11(i)(4)(C)(v).22
The Fund’s investments, including
derivatives, will be consistent with the
1940 Act and the Fund’s investment
objective and policies and will not be
16 Credit default swaps held by the Fund will be
traded on a U.S. Swap Execution Facility registered
with the Commodity Futures Trading Commission
(‘‘CFTC’’). The Fund may hold up to 10% of its net
assets in credit default swaps that are not
investment-grade at the time of purchase.
17 Interest rate swaps held by the Fund may
include listed swaps, centrally cleared OTC swaps,
or non-cleared OTC swaps. To the extent that the
Fund holds listed interest rate swaps, all such listed
swaps held by the Fund will be traded on a U.S.
Swap Execution Facility registered with the CFTC.
18 Options on U.S. Treasuries held by the Fund
may include listed or OTC options. The Fund will
attempt to limit counterparty risk in non-listed and
non-cleared OTC options contracts by entering into
such contracts only with counterparties the Adviser
believes are creditworthy and by limiting the
Fund’s exposure to each counterparty. The
Exchange represents that the Adviser will monitor
the creditworthiness of each counterparty and the
Fund’s exposure to each counterparty on an
ongoing basis.
19 The Fund will attempt to limit counterparty
risk in non-listed and non-cleared OTC swap
contracts by entering into such contracts only with
counterparties the Adviser believes are
creditworthy and by limiting the Fund’s exposure
to each counterparty. The Exchange represents that
the Adviser will monitor the creditworthiness of
each counterparty and the Fund’s exposure to each
counterparty on an ongoing basis. To the extent that
the Fund holds listed Inflation Swaps, all such
listed Inflation Swaps held by the Fund will be
traded on a U.S. Swap Execution Facility registered
with the CFTC. Inflation Swaps held by the Fund
will reference the Consumer Price Index For All
Urban Consumers (CPI–U).
20 See supra note 8.
21 See supra note 9.
22 See supra note 10.
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used to enhance leverage (although
certain derivatives and other
investments may result in leverage).23
That is, while the Fund will be
permitted to borrow as permitted under
the 1940 Act, the Fund’s investments
will not be used to seek performance
that is the multiple or inverse multiple
(i.e., 2Xs and 3Xs) of the Fund’s primary
broad-based securities benchmark index
(as defined in Form N–1A). The Fund
will only use those derivatives included
in the defined terms Inflation Swaps
and Other Derivatives. The Fund’s use
of derivative instruments will be
collateralized. In addition to the use
described above, the Fund will also use
derivative holdings for efficient
portfolio management, profit and gain
for the Fund, interest rate hedging, and
managing credit risk.
B. Exchange’s Description of the Fund’s
Other Investments
Under Normal Market Conditions, the
Fund may invest up to 20% of its net
assets in the following: One or more
ETFs,24 Equity Holdings, money market
mutual funds, including affiliated
money market mutual funds, bank
obligations, convertible securities
(including contingent convertible
securities), loan assignment and
participations, commitments to
purchase loan assignments, auction rate
securities, commercial paper, custodial
receipts, inverse floating rate
instruments, non-ETF investment
company securities, repurchase and
reverse repurchase agreements, shortterm funding agreements, structured
investments, synthetic variable rate
instruments, trust preferred securities,
when-issued securities, delayed
delivery securities, forward
commitments, pay-in-kind securities,
and deferred payment securities
(collectively, excluding ETFs and Equity
Holdings, ‘‘20% OTC Instruments’’).
23 The Fund will include appropriate risk
disclosure in its offering documents, including
leveraging risk. Leveraging risk is the risk that
certain transactions of a fund, including a fund’s
use of derivatives, may give rise to leverage, causing
a fund to be more volatile than if it had not been
leveraged. The Fund’s investments in derivative
instruments will be made in accordance with the
1940 Act and consistent with the Fund’s investment
objective and policies. To mitigate leveraging risk,
the Fund will segregate or earmark liquid assets
determined to be liquid by the Adviser in
accordance with procedures established by the
Trust’s Board and in accordance with the 1940 Act
(or, as permitted by applicable regulations, enter
into certain offsetting positions) to cover its
obligations under derivative instruments.
24 For purposes of this proposal, the term ‘‘ETF’’
includes Portfolio Depositary Receipts, Index Fund
Shares, and Managed Fund Shares as defined in
BZX Rules 14.11(b), (c), and (i), respectively, and
their equivalents on other national securities
exchanges.
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Fmt 4703
Sfmt 4703
The Fund may also engage in securities
lending.
C. Exchange’s Description of the
Application of the Generic Listing
Requirements
The Exchange represents that the
Shares will meet each of the initial and
continued listing criteria in BZX Rule
14.11(i), except that the Fund may not
comply with BZX Rules
14.11(i)(4)(C)(iv)(a),25
14.11(i)(4)(C)(iv)(b),26 and
14.11(i)(4)(C)(v).27 With respect to the
requirement in BZX Rule
14.11(i)(4)(C)(iv)(a) that at least 90% of
the weight of the listed derivatives
portion of the portfolio be in listed
derivatives for which the Exchange may
obtain information via ISG or for which
the principal market is a market with
which the Exchange has a
comprehensive surveillance sharing
agreement, the Exchange believes that
its surveillance procedures are adequate
to properly monitor the trading of the
Shares on the Exchange during all
trading sessions and to deter and detect
violations of Exchange rules and the
applicable federal securities laws.
Additionally, the Exchange represents
that all of the listed instruments that
would not meet this requirement would
nevertheless have a primary market that
is a swap execution facility that is
registered with and under the regulatory
oversight of the CFTC.28
The Exchange believes that the
liquidity in the Treasury futures,29
Eurodollar futures,30 and TIPS 31
markets mitigates the concern that BZX
Rule 14.11(i)(4)(C)(iv)(b) is intended to
address, and that such liquidity would
help prevent the Shares from being
susceptible to manipulation. Further,
the Exchange believes that for listed
swaps, including credit default swaps,
interest rate swaps, and Inflation Swaps,
the price transparency and surveillance
performed by the applicable swap
execution facility would similarly act to
mitigate the risk of manipulation of the
Shares. The Exchange also believes that
25 See
supra note 8.
supra note 9.
27 See supra note 10.
28 The Exchange represents that not all CFTC
registered swap execution facilities are members or
affiliates of members of the ISG.
29 According to the Exchange, in 2017, there were
approximately 744 million Treasury futures
contracts traded.
30 According to the Exchange, in 2017, there were
approximately 367 million Eurodollar futures
contracts traded.
31 According to the Exchange, in 2017, there were
approximately $17 billion worth of TIPS traded at
primary dealers on a daily basis.
26 See
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the size of the inflation swaps market,32
which would include all of the Inflation
Swaps that the Fund intends to invest
in, would also mitigate manipulation
concerns relating to both listed and OTC
Inflation Swaps held by the Fund.33
As it relates to BZX Rule
14.11(i)(4)(C)(v), which provides that
the notional value of OTC derivatives
shall not exceed 20% of the weight of
the portfolio (including gross notional
exposures), in an effort to minimize
exposure to potentially illiquid and
manipulable derivatives contracts, the
Exchange notes that the inflation swaps
market, which would include all of the
listed and OTC Inflation Swaps that the
Fund intends to invest in, is large and
liquid, which the Exchange believes
further mitigates the concerns which
BZX Rule 14.11(i)(4)(C)(v) is intended to
address. The Exchange also notes that
the Fund will attempt to limit
counterparty risk in non-cleared OTC
swap contracts, OTC Inflation Swaps,
and interest rate swaps, by entering into
such contracts only with counterparties
the Adviser believes are creditworthy
and by limiting the Fund’s exposure to
each counterparty. The Exchange also
notes that the Adviser will monitor the
creditworthiness of each counterparty
and the Fund’s exposure to each
counterparty on an ongoing basis.
Further, the Exchange notes that
notional principal never changes hands
in such swaps transactions, and it is a
theoretical value used to base the
exchanged payments. The Exchange
believes that a more accurate
representation of the swaps value in
order to monitor total counterparty risk
would be the mark-to market value of
the swap since inception, which the
Adviser generally expects to remain
below 15% of the Fund’s net assets.
The Exchange represents that, except
for the exceptions to BZX Rule
14.11(i)(4)(C) as described above, the
Fund’s proposed investments will
satisfy, on an initial and continued
listing basis, all of the generic listing
standards under BZX Rule 14.11(i)(4)(C)
and all other applicable requirements
for Managed Fund Shares under BZX
Rule 14.11(i). The Trust is required to
comply with Rule 10A–3 under the Act
32 For purposes of this discussion, the term
‘‘inflation swaps market’’ means any swap contract
that references either a measure of inflation, an
inflation index, or an instrument designed to
transfer inflation risk from one party to another.
33 According to publicly available numbers from
LCH. Clearnet Limited, which clears both listed and
OTC swaps, as of October 26, 2018, there had been
approximately $637 billion in U.S. dollardenominated inflation swaps traded year-to-date,
which would include the Inflation Swaps that the
Fund intends to invest in, cleared through their
platform alone.
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for the initial and continued listing of
the Shares of the Fund. In addition, the
Exchange represents that the Shares of
the Fund will comply with all other
requirements applicable to Managed
Fund Shares including, but not limited
to, requirements relating to the
dissemination of key information such
as the Disclosed Portfolio, NAV, and the
intraday indicative value (‘‘IIV’’), rules
governing the trading of equity
securities, trading hours, trading halts,
surveillance, firewalls, and the
information circular, as set forth in
Exchange rules applicable to Managed
Fund Shares and the orders approving
such rules. According to the Exchange,
at least 100,000 Shares will be
outstanding upon the commencement of
trading.
The Exchange further represents that
all of the ETFs, exchange-listed Equity
Holdings, futures contracts, and listed
options contracts held by the Fund will
trade on markets that are a member of
ISG or affiliated with a member of ISG
or with which the Exchange has in place
a comprehensive surveillance sharing
agreement.34 Additionally, the
Exchange or the Financial Industry
Regulatory Authority (‘‘FINRA’’), on
behalf of the Exchange, is able to access
as needed trade information for certain
fixed income instruments reported to
FINRA’s Trade Reporting and
Compliance Engine (‘‘TRACE’’) and
municipal securities reported to the
Municipal Securities Rulemaking
Board’s (‘‘MSRB’’) Electronic Municipal
Market Access system. FINRA may also
access data obtained from the MSRB
relating to municipal bond trading
activity for surveillance purposes in
connection with trading in the Shares.
III. Discussion and Commission’s
Findings
After careful review, the Commission
finds that the Exchange’s proposal to list
and trade the Shares, as modified by
Amendment No. 1, is consistent with
the Act and the rules and regulations
thereunder applicable to a national
securities exchange.35 In particular, the
Commission finds that the proposed
rule change, as modified by Amendment
No. 1, is consistent with Section 6(b)(5)
of the Act,36 which requires, among
34 For a list of the current members and affiliate
members of ISG, see www.isgportal.com. The
Exchange notes that not all components of the
Disclosed Portfolio for the Fund may trade on
markets that are members of ISG or with which the
Exchange has in place a comprehensive
surveillance sharing agreement.
35 In approving this proposed rule change, the
Commission notes that it has considered the
proposed rule’s impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
36 15 U.S.C. 78f(b)(5).
PO 00000
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6029
other things, that the Exchange’s rules
be designed to prevent fraudulent and
manipulative acts and practices, 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.
As noted above, the Fund may hold
up to 100% Inflation Swaps and Other
Derivatives 37 in a manner that may not
comply with the generic listing
requirements in Rules
14.11(i)(4)(C)(iv)(a), 14.11(i)(4)(C)(iv)(b),
and 14.11(i)(4)(C)(v).38 The Exchange
states that the Fund will only use those
derivatives included in the defined term
Inflation Hedging Instruments and
Other Derivatives in order to attempt to
mitigate the inflation risk of the U.S.
dollar-denominated bonds to which the
Fund will have exposure. The Exchange
states that the Fund’s use of derivative
instruments will be collateralized. In
addition, the Exchange represents that
the Shares of the Fund will comply with
all other requirements applicable to
Managed Fund Shares including, but
not limited to, requirements relating to
the dissemination of key information
such as the Disclosed Portfolio, NAV,
IIV, rules governing the trading of equity
securities, trading hours, trading halts,
surveillance, firewalls, and the
information circular.
The Exchange states that the Fund’s
Inflation Swaps and Other Derivatives
will not meet the generic listing
requirement that at least 90% of the
weight of the listed derivatives portion
of the portfolio be in listed derivatives
for which the Exchange may obtain
information via ISG from other members
or affiliates of the ISG or for which the
principal market is a market with which
the Exchange has a comprehensive
37 The Exchange states that the Fund’s
investments, including derivative instruments will
be made in accordance with the 1940 Act and
consistent with the Fund’s investment objective and
policies. To mitigate leveraging risk, the Fund will
segregate or earmark liquid assets determined to be
liquid by the Adviser in accordance with
procedures established by the Trust’s Board and in
accordance with the 1940 Act to cover its
obligations under derivative instruments.
38 The Commission notes that it has previously
approved other proposals to list and trade series of
Managed Fund Shares based on a portfolio
containing securities and instruments substantially
similar to Bonds, Inflation Hedging Instruments,
and Other Derivatives. See, e.g., Securities
Exchange Act Release Nos. 76719 (December 21,
2015), 80 FR 80859 (December 28, 2015)
(NYSEArca–2015–73) (order approving listing and
trading of the Guggenheim Total Return ETF) and
77522 (April 5, 2016), 81 FR 21420 (April 11, 2016)
(NYSEArca–2015–125) (order approving listing and
trading of the RiverFront Dynamic Unconstrained
Income ETF and RiverFront Dynamic Core Income
ETF).
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surveillance sharing agreement. The
Exchange represents that its
surveillance procedures are adequate to
properly monitor the trading of the
Shares on the Exchange during all
trading sessions and to deter and detect
violations of Exchange rules and the
applicable federal securities laws. The
Exchange also represents that all of the
listed instruments that would not meet
this requirement would nevertheless
have a primary market that is a swap
execution facility that is registered with
and under the regulatory oversight of
the CFTC.39
The Exchange states that the Fund’s
investments in Inflation Swaps and
Other Derivatives will not meet the
generic listing requirement that the
aggregate gross notional value of listed
derivatives based on any five or fewer
underlying reference assets shall not
exceed 65% of the weight of the
portfolio and that the aggregate gross
notional value of listed derivatives
based on any single underlying
reference asset not exceed 30% of the
weight of the portfolio. The Exchange
states that it believes the liquidity in the
Treasury futures, Eurodollar futures,
and TIPS markets mitigates
manipulation concerns. The Exchange
further believes that for listed swaps,
including credit default swaps, interest
rate swaps, and Inflation Swaps, the
price transparency and surveillance
performed by the applicable swap
execution facility would similarly act to
mitigate the risk of manipulation of the
Shares. The Exchange also states that it
believes that the size of the inflation
swaps market, which would include all
of the Inflation Swaps that the Fund
intends to invest in, also mitigates
manipulation concerns relating to both
listed and OTC Inflation Swaps held by
the Fund.
The Exchange states that the Fund’s
holdings in OTC derivatives will exceed
20% of the weight of the portfolio and,
therefore, not meet the generic listing
requirements. The Exchange states that
the Fund will attempt to limit
counterparty risk in non-cleared OTC
swaps and OTC Inflation Swaps and
interest rate swaps by entering into such
contracts only with counterparties the
Adviser believes are creditworthy and
by limiting the Fund’s exposure to each
counterparty, and that the Adviser will
monitor the creditworthiness of each
counterparty and the Fund’s exposure to
each counterparty on an ongoing basis.
The Exchange states that the inflation
swaps market, which would include all
of the listed and OTC Inflation Swaps
that the Fund intends to invest in, is
39 See
supra note 28.
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large and liquid, which the Exchange
believes mitigates the concerns the 20%
limitation is intended to address.
The Commission also finds that the
proposal to list and trade the Shares on
the Exchange is consistent with Section
11A(a)(1)(C)(iii) of the Act 40 which sets
forth Congress’ 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. The
Exchange represents that the intra-day,
closing and settlement prices of
exchange-traded portfolio assets,
including exchange-listed Equity
Holdings, ETFs, options, and futures,
will be readily available from the
securities exchanges and futures
exchanges trading such securities and
futures, as the case may be, automated
quotation systems, published or other
public sources, or online information
services such as Bloomberg or Reuters.
Intraday price quotations on both listed
and OTC swaps, TIPS, 20% OTC
Instruments, Bonds, Equity Holdings
that are not exchange-listed, and fixed
income instruments are available from
major broker-dealer firms and from
third-parties, which may provide prices
free with a time delay or in real-time for
a paid fee. Trade price and other
information relating to municipal
securities is available through the
MSRB.
In addition, the Disclosed Portfolio
will be available on the issuer’s website
free of charge. The Fund’s website
includes a form of the prospectus for the
Fund and additional information related
to NAV and other applicable
quantitative information. Information
regarding market price and trading
volume of the Shares will be
continuously available throughout the
day on brokers’ computer screens and
other electronic services. Quotation and
last-sale information on the Shares will
be available through the Consolidated
Tape Association. Information regarding
the previous day’s closing price and
trading volume for the Shares will be
published daily in the financial section
of newspapers. Quotation and last-sale
information for listed options contracts
cleared by the Options Clearing
Corporation will be available via the
Options Price Reporting Authority.
Further, trading in the Shares may be
halted for market conditions or for
reasons that, in the view of the
Exchange, make trading inadvisable.
The Exchange deems the Shares to be
40 15
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equity securities, thus rendering trading
in the Shares subject to the Exchange’s
existing rules governing the trading of
equity securities. The Exchange
represents that it has appropriate rules
to facilitate trading in the Shares during
all trading sessions.
The Exchange has made the following
representations in support of its
proposal:
(1) Other than BZX Rules
14.11(i)(4)(C)(iv)(a), 14.11(i)(4)(C)(iv)(b), and
14.11(i)(4)(C)(v), the Fund will comply with
all other requirements on an initial and
continued listing basis for Managed Fund
Shares under BZX Rule 14.11(i), including
those requirements regarding the Disclosed
Portfolio and the requirement that the
Disclosed Portfolio and the NAV will be
made available to all market participants at
the same time,41 IIV,42 suspension of trading
or removal,43 trading halts,44 disclosure,45
and firewalls.46
(2) Trading of the Shares on the Exchange
will be subject to the Exchange’s surveillance
procedures for derivative products, including
Managed Fund Shares, and these procedures
are adequate to properly monitor the trading
of the Shares on the Exchange during all
trading sessions and to deter and detect
violations of Exchange rules and the
applicable federal securities laws.
(3) All of the ETFs, exchange-listed Equity
Holdings, futures contracts, and listed
options contracts held by the Fund will trade
on markets that are a member of ISG or
affiliated with a member of ISG or with
which the Exchange has in place a
comprehensive surveillance sharing
agreement. Additionally, the Exchange or
FINRA, on behalf of the Exchange, are able
to access, as needed, trade information for
certain fixed income instruments reported to
FINRA’s TRACE and municipal securities
reported to the MSRB’s Electronic Municipal
Market Access system. FINRA also can access
data obtained from the MSRB relating to
municipal bond trading activity for
surveillance purposes in connection with
trading in the Shares. The Exchange has a
policy prohibiting the distribution of
material, non-public information by its
employees.
(4) Certain of the listed Inflation Swaps,
listed credit default swaps, and listed interest
rate swaps held by the Fund will trade on
markets that are a member of ISG or affiliated
with a member of ISG or with which the
Exchange has in place a comprehensive
surveillance sharing agreement. The
Exchange, FINRA, on behalf of the Exchange,
or both will communicate regarding trading
in the Shares and in certain of the listed
Inflation Swaps, credit default swaps, and
listed interest rate swaps held by the Fund
with the ISG, other markets or entities who
are members or affiliates of the ISG, or with
41 See BZX Rules 14.11(i)(4)(A)(ii) and
14.11(i)(4)(B)(ii).
42 See BZX Rule 14.11(i)(4)(B)(i).
43 See BZX Rule 14.11(i)(4)(B)(iii).
44 See BZX Rule 14.11(i)(4)(B)(iv).
45 See BZX Rule 14.11(i)(6).
46 See BZX Rule 14.11(i)(7).
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which the Exchange has entered into a
comprehensive surveillance sharing
agreement.
(5) 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 will discuss the
following: (a) The procedures for purchases
and redemptions of Shares in Creation Units
(and that Shares are not individually
redeemable); (b) BZX Rule 3.7, which
imposes suitability obligations on Exchange
members with respect to recommending
transactions in the Shares to customers; (c)
how information regarding the IIV and the
Disclosed Portfolio is disseminated; (d) the
risks involved in trading the Shares during
the Pre-Opening 47 and After Hours Trading
Sessions 48 when an updated IIV 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.
(6) The Fund’s investments, including
derivatives, will be consistent with the 1940
Act and the Fund’s investment objective and
policies and will not be used to enhance
leverage (although certain derivatives and
other investments may result in leverage).49
(7) The Fund’s investments will not be
used to seek performance that is the multiple
or inverse multiple (i.e., 2Xs and 3Xs) of the
Fund’s primary broad-based securities
benchmark index (as defined in Form N–1A).
(8) Credit default swaps held by the Fund
will be traded on a U.S. Swap Execution
Facility registered with the CFTC. At least
90% of the Fund’s net assets in credit default
swaps will be investment-grade at the time of
purchase.
(9) To the extent that the Fund holds listed
Inflation Swaps or interest rate swaps, all
such listed Inflation Swaps and listed
interest rate swaps held by the Fund will be
traded on a U.S. Swap Execution Facility
registered with the CFTC.
(10) The Trust is required to comply with
Rule 10A–3 under the Act 50 for the initial
and continued listing of the Shares of the
Fund, and at least 100,000 Shares will be
outstanding upon the commencement of
trading.
The Exchange represents that all
statements and representations made in
this filing regarding the description of
the portfolio or reference assets,
limitations on portfolio holdings or
reference assets, dissemination and
availability of index, reference asset,
and intraday indicative values, and the
applicability of Exchange rules specified
in this filing shall constitute continued
listing requirements for the Fund. In
addition, the issuer has represented to
47 The Pre-Opening Session is from 8:00 a.m. to
9:30 a.m. Eastern Time.
48 The After Hours Trading Session is from 4:00
p.m. to 5:00 p.m. Eastern Time.
49 See supra note 23.
50 See 17 CFR 240.10A–3.
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the Exchange that it will advise the
Exchange of any failure by the Fund or
the Shares to comply with the
continued listing requirements, and,
pursuant to its obligations under
Section 19(g)(1) of the Act, the Exchange
will surveil for compliance with the
continued listing requirements. If the
Fund or the Shares are not in
compliance with the applicable listing
requirements, the Exchange will
commence delisting procedures under
BZX Rule 14.12.
This approval order is based on all of
the Exchange’s representations and
descriptions of the Shares and the Fund,
including those set forth above and in
Amendment No. 1 to the proposed rule
change. Except as described herein, the
Commission notes that the Shares must
comply with all applicable requirements
of BZX Rule 14.11(i) 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
No. 1, is consistent with Section
11A(a)(1)(C)(iii) of the Act 51 and
Section 6(b)(5) of the Act 52 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 Act,53 that the
proposed rule change (SR–CboeBZX–
2018–077), as modified by Amendment
No. 1, be, and it hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.54
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019–03175 Filed 2–22–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
33377; 812–14850]
CM Finance Inc, et al.
February 19, 2019.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice.
AGENCY:
Notice of application for an order
under sections 17(d) and 57(i) of the
Investment Company Act of 1940 (the
51 15
U.S.C. 78k–1(a)(1)(C)(iii).
U.S.C. 78f(b)(5).
53 15 U.S.C. 78s(b)(2).
54 17 CFR 200.30–3(a)(12).
52 15
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6031
‘‘Act’’) and rule 17d–1 under the Act
permitting certain joint transactions
otherwise prohibited by sections 17(d)
and 57(a)(4) of the Act and under rule
17d–1 under the Act.
SUMMARY OF APPLICATION: Applicants
request an order to permit certain
closed-end management investment
companies to co-invest in portfolio
companies with each other and with
affiliated investment funds.
APPLICANTS: CM Finance Inc (‘‘CMFN’’),
CM Credit Opportunities BDC I Inc.
(‘‘CM Credit’’ and together with CMFN,
the ‘‘Existing Regulated Funds’’), CM
Investment Partners LLC (‘‘CM
Adviser’’) on behalf of itself and its
successors,1 CM Credit Opportunity
Fund I LLC (the ‘‘Existing Affiliated
Fund’’), and CM Finance SPV Ltd. (‘‘CM
SPV’’), a Wholly-Owned Investment Sub
(defined below) of CMFN.
FILING DATES: The application was filed
on December 13, 2017, and amended on
April 30, 2018 and October 25, 2018.
HEARING OR NOTIFICATION OF HEARING: An
order granting the requested relief will
be issued unless the Commission orders
a hearing. Interested persons may
request a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on March 18, 2019, and
should be accompanied by proof of
service on applicants, in the form of an
affidavit or, for lawyers, a certificate of
service. Pursuant to rule 0–5 under the
Act, hearing requests should state the
nature of the writer’s interest, any facts
bearing upon the desirability of a
hearing on the matter, the reason for the
request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F St.
NE, Washington, DC 20549–1090.
Applicants: 601 Lexington Avenue, 26th
Floor, New York, NY 10022.
FOR FURTHER INFORMATION CONTACT:
Laura L. Solomon, Senior Counsel, at
(202) 551–6915 or David J. Marcinkus,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
1 The term ‘‘successor,’’ as applied to each
Adviser (as defined below), means an entity that
results from a reorganization into another
jurisdiction or change in the type of business
organization.
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Agencies
[Federal Register Volume 84, Number 37 (Monday, February 25, 2019)]
[Notices]
[Pages 6026-6031]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-03175]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-85166; File No. SR-CboeBZX-2018-077]
Self-Regulatory Organizations; Cboe BZX Exchange, Inc.; Order
Granting Approval of a Proposed Rule Change, as Modified by Amendment
No. 1, To List and Trade Shares of the JPMorgan Inflation Managed Bond
ETF of the J.P. Morgan Exchange-Traded Fund Trust Under Rule 14.11(i),
Managed Fund Shares
February 19, 2019.
I. Introduction
On November 2, 2018, Cboe BZX Exchange, Inc. (``Exchange'' or
``BZX'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change to list and trade shares (``Shares'') of the
JPMorgan Inflation Managed Bond ETF (``Fund'') of the J.P. Morgan
Exchange-Traded Fund Trust (``Trust'') under Rule 14.11(i) (``Managed
Fund Shares'').
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
The proposed rule change was published for comment in the Federal
Register on November 21, 2018.\3\ On December 10, 2018, the Exchange
filed Amendment No. 1 to the proposed rule change.\4\ On December 21,
2018, the
[[Page 6027]]
Commission extended the time 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.\5\ The Commission has received no comments on the proposal, as
modified by Amendment No. 1. This order grants approval of the proposed
rule change, as modified by Amendment No. 1.
---------------------------------------------------------------------------
\3\ See Securities Exchange Act Release No. 84604 (November 15,
2018), 83 FR 58789 (``Notice'').
\4\ In Amendment No. 1, which amended and replaced the proposed
rule change in its entirety, the Exchange: (a) Amended the universe
of Equity Holdings (as defined herein); (b) stated where intraday
price quotations for Bonds (as defined herein) and Equity Holdings
that are not exchange-traded could be found; (c) represented that
the Equity Holdings held by the Fund that will trade on markets that
are a member of Intermarket Surveillance Group (``ISG'') or
affiliated with a member of ISG or with which the Exchange has in
place a comprehensive surveillance sharing agreement would be the
exchange-listed Equity Holdings; and (d) made technical and
conforming changes. Because Amendment No. 1 does not materially
alter the substance of the proposed rule change or raise unique or
novel regulatory issues under the Act, Amendment No. 1 is not
subject to notice and comment. Amendment No. 1 to the proposed rule
change is available at: https://www.sec.gov/comments/SR-cboebzx-2018-077/srcboebzx2018077-4777675-176818.pdf.
\5\ See Securities Exchange Act Release No. 84944, 83 FR 67751
(December 31, 2018).
---------------------------------------------------------------------------
II. Exchange's Description of the Proposed Rule Change, as Modified by
Amendment No. 1
The Exchange proposes to list and trade the Shares of the Fund
pursuant to BZX Rule 14.11(i), which governs the listing and trading of
Managed Fund Shares on the Exchange. The Shares will be offered by the
Trust, which was established as a Delaware statutory trust.\6\ The Fund
will be an actively managed exchange-traded fund. J.P Morgan Investment
Management, Inc. is the investment adviser (``Adviser'') and the
administrator to the Fund. JPMorgan Chase Bank, N.A. is the custodian
and transfer agent for the Trust. JPMorgan Distribution Services, Inc.
serves as the distributor for the Trust. The Exchange represents the
Adviser is not a broker-dealer, but is affiliated with multiple broker-
dealers and has implemented and will maintain ``fire walls'' with
respect to such broker-dealers regarding access to information
concerning the composition of, and/or changes to, the Fund's portfolio.
In addition, Adviser personnel who make decisions regarding the Fund's
portfolio are subject to procedures designed to prevent the use and
dissemination of material, non-public information regarding the Fund's
portfolio.\7\
---------------------------------------------------------------------------
\6\ The Exchange represents that the Trust is registered under
the Investment Company Act of 1940 (``1940 Act''). See Registration
Statement on Form N-1A for the Trust, dated July 31, 2018 (File Nos.
333-191837 and 811-22903) (``Registration Statement''). The Exchange
further represents that the Trust has obtained certain exemptive
relief under the 1940 Act.
\7\ See BZX Rule 14.11(i)(7). The Exchange further represents
that, in the event that (a) the Adviser becomes registered as a
broker-dealer or newly affiliated with another broker-dealer, or (b)
any new adviser or sub-adviser is a registered broker-dealer or
becomes affiliated with a broker-dealer, it will implement and
maintain a fire wall with respect to its relevant personnel or such
broker-dealer affiliate, as applicable, regarding access to
information concerning the composition of, and/or changes to, the
portfolio, and will be subject to procedures designed to prevent the
use and dissemination of material, non-public information regarding
such portfolio.
---------------------------------------------------------------------------
Under the proposal, the Exchange seeks to permit the Fund to hold
Inflation Swaps and Other Derivatives, each as defined below, in a
manner that may not comply with BZX Rules 14.11(i)(4)(C)(iv)(a),\8\
14.11(i)(4)(C)(iv)(b),\9\ and/or 14.11(i)(4)(C)(v),\10\ as further
described below.\11\ Otherwise, the Exchange represents that the Fund
will comply with all other listing requirements on an initial and
continued listing basis under BZX Rule 14.11(i).
---------------------------------------------------------------------------
\8\ BZX Rule 14.11(i)(4)(C)(iv)(a) provides that ``there shall
be no limitation to the percentage of the portfolio invested in such
holdings; provided, however, that in the aggregate, at least 90% of
the weight of such holdings invested in futures, exchange-traded
options, and listed swaps shall, on both an initial and continuing
basis, consist of futures, options, and swaps for which the Exchange
may obtain information via the ISG from other members or affiliates
of the ISG or for which the principal market is a market with which
the Exchange has a comprehensive surveillance sharing agreement,
calculated using the aggregate gross notional value of such
holdings.'' The Exchange is proposing that the Fund be exempt from
this requirement only as it relates to the Fund's holdings in
certain credit default swaps, interest rate swaps, and Inflation
Swaps, as further described below.
\9\ BZX Rule 14.11(i)(4)(C)(iv)(b) provides that ``the aggregate
gross notional value of listed derivatives based on any five or
fewer underlying reference assets shall not exceed 65% of the weight
of the portfolio (including gross notional exposures), and the
aggregate gross notional value of listed derivatives based on any
single underlying reference asset shall not exceed 30% of the weight
of the portfolio (including gross notional exposures).'' The
Exchange is proposing that the Fund would meet neither the 65% nor
the 30% requirements of BZX Rule 14.11(i)(4)(C)(iv)(b).
Specifically, the Exchange is proposing that the Fund be exempt from
this requirement as it relates to the Fund's holdings in listed
derivatives, which include U.S. Treasury futures, Eurodollar
futures, options on U.S. Treasuries and Treasury futures, credit
default swaps, and certain Inflation Swaps and interest rate swaps,
as further described below, which could constitute as much as 100%
of the weight of the portfolio (including gross notional exposures)
based on a single underlying reference asset.
\10\ BZX Rule 14.11(i)(4)(C)(v) provides that ``the portfolio
may, on both an initial and continuing basis, hold OTC derivatives,
including forwards, options, and swaps on commodities, currencies
and financial instruments (e.g., stocks, fixed income, interest
rates, and volatility) or a basket or index of any of the foregoing,
however the aggregate gross notional value of OTC derivatives shall
not exceed 20% of the weight of the portfolio (including gross
notional exposures).'' The Exchange is proposing that the Fund be
exempt from this requirement as it relates to the Fund's holdings in
OTC derivatives, which could constitute as much as 75% of the weight
of the portfolio (including gross notional exposures).
\11\ The Adviser notes that the Fund may by virtue of its
holdings be issued certain exchange-listed or OTC equity
instruments, including common and preferred stock, common stock
warrants and rights, and securities issued by real estate investment
trusts (collectively, ``Equity Holdings''), that may not meet the
requirements of Rule 14.11(i)(4)(C)(i). The Fund will not purchase
such instruments and will dispose of such holdings as the Adviser
determines is in the best interest of the Fund's shareholders.
Equity Holdings will not constitute more than 10% of the Fund's net
assets. The Adviser expects that the Fund will generally acquire
Equity Holdings through issuances that it receives by virtue of its
other holdings, such as corporate actions or convertible securities.
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A. Exchange's Description of the Fund's Primary Investments \12\
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\12\ The Commission notes that additional information regarding
the Fund, 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 Amendment No. 1 to the proposed rule change and the
Registration Statement, as applicable. See Amendment No. 1 and
Registration Statement, supra notes 4 and 6, respectively.
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According to the Exchange, the Fund is designed to protect the
total return \13\ generated by its fixed income holdings from inflation
risk and will seek to maximize inflation protected total return. The
Fund seeks to achieve its investment objective by investing, under
Normal Market Conditions,\14\ at least 80% of its net assets in
Bonds,\15\ Inflation Hedging Instruments, and Other Derivatives, as
defined below.
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\13\ According to the Exchange, total return includes income and
capital appreciation.
\14\ As defined in BZX Rule 14.11(i)(3)(E), the term ``Normal
Market Conditions'' includes, but is not limited to, the absence of
trading halts in the applicable financial markets generally;
operational issues causing dissemination of inaccurate market
information or system failures; or force majeure type events such as
natural or man-made disaster, act of God, armed conflict, act of
terrorism, riot or labor disruption, or any similar intervening
circumstance.
\15\ For purposes of this proposal, the term ``Bond'' includes
only the following U.S. dollar denominated instruments issued by the
U.S. Government or its agencies and instrumentalities, a domestic or
a foreign corporation or a municipality: Corporate bonds, U.S.
government and agency debt securities (excluding Treasury Inflation
Protected Securities (``TIPS''), which, as described below, may be
held by the Fund in order to attempt to mitigate inflation risk),
asset-backed securities, and mortgage-related and mortgage-backed
securities. Mortgage-related and mortgage-backed securities may be
structured as collateralized mortgage obligations (agency and non-
agency), stripped mortgage-backed securities (interest-only or
principal-only), commercial mortgage-backed securities, mortgage
pass-through securities, collateralized mortgage obligations,
adjustable rate mortgages, convertible bonds, and zero-coupon
obligations. The Exchange notes that the Fund's holdings in Bonds
will meet the requirements of BZX Rule 14.11(i)(4)(C)(ii)(a)-(e)
related to the fixed income securities portion of the Fund,
including the requirement that non-agency, non-GSE, and privately-
issued mortgage-related and other asset-backed securities components
of a portfolio shall not account, in the aggregate, for more than
20% of the weight of the fixed income portion of the portfolio.
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The Fund will gain exposure to U.S. dollar-denominated bonds
primarily through investing directly in Bonds. Up to 10% of the Fund's
total assets may be invested in securities rated below investment grade
(junk bonds). Junk bonds are rated in the fifth or lower rated
categories (for example, BB+ or
[[Page 6028]]
lower by Standard & Poor's Ratings Services and Ba1 or lower by
Moody's). The Fund may also use the following instruments to gain
exposure to credit or interest rates: Credit default swaps,\16\
interest rate swaps,\17\ Eurodollar futures, U.S. Treasury futures,
options on U.S. Treasury Futures, and options on U.S. Treasuries \18\
(collectively, ``Other Derivatives'').
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\16\ Credit default swaps held by the Fund will be traded on a
U.S. Swap Execution Facility registered with the Commodity Futures
Trading Commission (``CFTC''). The Fund may hold up to 10% of its
net assets in credit default swaps that are not investment-grade at
the time of purchase.
\17\ Interest rate swaps held by the Fund may include listed
swaps, centrally cleared OTC swaps, or non-cleared OTC swaps. To the
extent that the Fund holds listed interest rate swaps, all such
listed swaps held by the Fund will be traded on a U.S. Swap
Execution Facility registered with the CFTC.
\18\ Options on U.S. Treasuries held by the Fund may include
listed or OTC options. The Fund will attempt to limit counterparty
risk in non-listed and non-cleared OTC options contracts by entering
into such contracts only with counterparties the Adviser believes
are creditworthy and by limiting the Fund's exposure to each
counterparty. The Exchange represents that the Adviser will monitor
the creditworthiness of each counterparty and the Fund's exposure to
each counterparty on an ongoing basis.
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The Fund will attempt to mitigate the inflation risk of the Fund's
exposure to Bonds primarily through the use of either over-the-counter
(``OTC'') or listed inflation swaps (``Inflation Swaps''),\19\ which
are managed on an active basis. Additionally, the Fund may also attempt
to mitigate inflation risk through investing in TIPS (together with
Inflation Swaps, collectively, ``Inflation Hedging Instruments''). The
Exchange is proposing to allow the Fund to hold up to 100% of the
weight of its portfolio (including gross notional exposure) in
Inflation Swaps and Other Derivatives, collectively, in a manner that
may not comply with BZX Rules 14.11(i)(4)(C)(iv)(a),\20\
14.11(i)(4)(C)(iv)(b),\21\ and/or 14.11(i)(4)(C)(v).\22\
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\19\ The Fund will attempt to limit counterparty risk in non-
listed and non-cleared OTC swap contracts by entering into such
contracts only with counterparties the Adviser believes are
creditworthy and by limiting the Fund's exposure to each
counterparty. The Exchange represents that the Adviser will monitor
the creditworthiness of each counterparty and the Fund's exposure to
each counterparty on an ongoing basis. To the extent that the Fund
holds listed Inflation Swaps, all such listed Inflation Swaps held
by the Fund will be traded on a U.S. Swap Execution Facility
registered with the CFTC. Inflation Swaps held by the Fund will
reference the Consumer Price Index For All Urban Consumers (CPI-U).
\20\ See supra note 8.
\21\ See supra note 9.
\22\ See supra note 10.
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The Fund's investments, including derivatives, will be consistent
with the 1940 Act and the Fund's investment objective and policies and
will not be used to enhance leverage (although certain derivatives and
other investments may result in leverage).\23\ That is, while the Fund
will be permitted to borrow as permitted under the 1940 Act, the Fund's
investments will not be used to seek performance that is the multiple
or inverse multiple (i.e., 2Xs and 3Xs) of the Fund's primary broad-
based securities benchmark index (as defined in Form N-1A). The Fund
will only use those derivatives included in the defined terms Inflation
Swaps and Other Derivatives. The Fund's use of derivative instruments
will be collateralized. In addition to the use described above, the
Fund will also use derivative holdings for efficient portfolio
management, profit and gain for the Fund, interest rate hedging, and
managing credit risk.
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\23\ The Fund will include appropriate risk disclosure in its
offering documents, including leveraging risk. Leveraging risk is
the risk that certain transactions of a fund, including a fund's use
of derivatives, may give rise to leverage, causing a fund to be more
volatile than if it had not been leveraged. The Fund's investments
in derivative instruments will be made in accordance with the 1940
Act and consistent with the Fund's investment objective and
policies. To mitigate leveraging risk, the Fund will segregate or
earmark liquid assets determined to be liquid by the Adviser in
accordance with procedures established by the Trust's Board and in
accordance with the 1940 Act (or, as permitted by applicable
regulations, enter into certain offsetting positions) to cover its
obligations under derivative instruments.
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B. Exchange's Description of the Fund's Other Investments
Under Normal Market Conditions, the Fund may invest up to 20% of
its net assets in the following: One or more ETFs,\24\ Equity Holdings,
money market mutual funds, including affiliated money market mutual
funds, bank obligations, convertible securities (including contingent
convertible securities), loan assignment and participations,
commitments to purchase loan assignments, auction rate securities,
commercial paper, custodial receipts, inverse floating rate
instruments, non-ETF investment company securities, repurchase and
reverse repurchase agreements, short-term funding agreements,
structured investments, synthetic variable rate instruments, trust
preferred securities, when-issued securities, delayed delivery
securities, forward commitments, pay-in-kind securities, and deferred
payment securities (collectively, excluding ETFs and Equity Holdings,
``20% OTC Instruments''). The Fund may also engage in securities
lending.
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\24\ For purposes of this proposal, the term ``ETF'' includes
Portfolio Depositary Receipts, Index Fund Shares, and Managed Fund
Shares as defined in BZX Rules 14.11(b), (c), and (i), respectively,
and their equivalents on other national securities exchanges.
---------------------------------------------------------------------------
C. Exchange's Description of the Application of the Generic Listing
Requirements
The Exchange represents that the Shares will meet each of the
initial and continued listing criteria in BZX Rule 14.11(i), except
that the Fund may not comply with BZX Rules 14.11(i)(4)(C)(iv)(a),\25\
14.11(i)(4)(C)(iv)(b),\26\ and 14.11(i)(4)(C)(v).\27\ With respect to
the requirement in BZX Rule 14.11(i)(4)(C)(iv)(a) that at least 90% of
the weight of the listed derivatives portion of the portfolio be in
listed derivatives for which the Exchange may obtain information via
ISG or for which the principal market is a market with which the
Exchange has a comprehensive surveillance sharing agreement, the
Exchange believes that its surveillance procedures are adequate to
properly monitor the trading of the Shares on the Exchange during all
trading sessions and to deter and detect violations of Exchange rules
and the applicable federal securities laws. Additionally, the Exchange
represents that all of the listed instruments that would not meet this
requirement would nevertheless have a primary market that is a swap
execution facility that is registered with and under the regulatory
oversight of the CFTC.\28\
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\25\ See supra note 8.
\26\ See supra note 9.
\27\ See supra note 10.
\28\ The Exchange represents that not all CFTC registered swap
execution facilities are members or affiliates of members of the
ISG.
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The Exchange believes that the liquidity in the Treasury
futures,\29\ Eurodollar futures,\30\ and TIPS \31\ markets mitigates
the concern that BZX Rule 14.11(i)(4)(C)(iv)(b) is intended to address,
and that such liquidity would help prevent the Shares from being
susceptible to manipulation. Further, the Exchange believes that for
listed swaps, including credit default swaps, interest rate swaps, and
Inflation Swaps, the price transparency and surveillance performed by
the applicable swap execution facility would similarly act to mitigate
the risk of manipulation of the Shares. The Exchange also believes that
[[Page 6029]]
the size of the inflation swaps market,\32\ which would include all of
the Inflation Swaps that the Fund intends to invest in, would also
mitigate manipulation concerns relating to both listed and OTC
Inflation Swaps held by the Fund.\33\
---------------------------------------------------------------------------
\29\ According to the Exchange, in 2017, there were
approximately 744 million Treasury futures contracts traded.
\30\ According to the Exchange, in 2017, there were
approximately 367 million Eurodollar futures contracts traded.
\31\ According to the Exchange, in 2017, there were
approximately $17 billion worth of TIPS traded at primary dealers on
a daily basis.
\32\ For purposes of this discussion, the term ``inflation swaps
market'' means any swap contract that references either a measure of
inflation, an inflation index, or an instrument designed to transfer
inflation risk from one party to another.
\33\ According to publicly available numbers from LCH. Clearnet
Limited, which clears both listed and OTC swaps, as of October 26,
2018, there had been approximately $637 billion in U.S. dollar-
denominated inflation swaps traded year-to-date, which would include
the Inflation Swaps that the Fund intends to invest in, cleared
through their platform alone.
---------------------------------------------------------------------------
As it relates to BZX Rule 14.11(i)(4)(C)(v), which provides that
the notional value of OTC derivatives shall not exceed 20% of the
weight of the portfolio (including gross notional exposures), in an
effort to minimize exposure to potentially illiquid and manipulable
derivatives contracts, the Exchange notes that the inflation swaps
market, which would include all of the listed and OTC Inflation Swaps
that the Fund intends to invest in, is large and liquid, which the
Exchange believes further mitigates the concerns which BZX Rule
14.11(i)(4)(C)(v) is intended to address. The Exchange also notes that
the Fund will attempt to limit counterparty risk in non-cleared OTC
swap contracts, OTC Inflation Swaps, and interest rate swaps, by
entering into such contracts only with counterparties the Adviser
believes are creditworthy and by limiting the Fund's exposure to each
counterparty. The Exchange also notes that the Adviser will monitor the
creditworthiness of each counterparty and the Fund's exposure to each
counterparty on an ongoing basis. Further, the Exchange notes that
notional principal never changes hands in such swaps transactions, and
it is a theoretical value used to base the exchanged payments. The
Exchange believes that a more accurate representation of the swaps
value in order to monitor total counterparty risk would be the mark-to
market value of the swap since inception, which the Adviser generally
expects to remain below 15% of the Fund's net assets.
The Exchange represents that, except for the exceptions to BZX Rule
14.11(i)(4)(C) as described above, the Fund's proposed investments will
satisfy, on an initial and continued listing basis, all of the generic
listing standards under BZX Rule 14.11(i)(4)(C) and all other
applicable requirements for Managed Fund Shares under BZX Rule
14.11(i). The Trust is required to comply with Rule 10A-3 under the Act
for the initial and continued listing of the Shares of the Fund. In
addition, the Exchange represents that the Shares of the Fund will
comply with all other requirements applicable to Managed Fund Shares
including, but not limited to, requirements relating to the
dissemination of key information such as the Disclosed Portfolio, NAV,
and the intraday indicative value (``IIV''), rules governing the
trading of equity securities, trading hours, trading halts,
surveillance, firewalls, and the information circular, as set forth in
Exchange rules applicable to Managed Fund Shares and the orders
approving such rules. According to the Exchange, at least 100,000
Shares will be outstanding upon the commencement of trading.
The Exchange further represents that all of the ETFs, exchange-
listed Equity Holdings, futures contracts, and listed options contracts
held by the Fund will trade on markets that are a member of ISG or
affiliated with a member of ISG or with which the Exchange has in place
a comprehensive surveillance sharing agreement.\34\ Additionally, the
Exchange or the Financial Industry Regulatory Authority (``FINRA''), on
behalf of the Exchange, is able to access as needed trade information
for certain fixed income instruments reported to FINRA's Trade
Reporting and Compliance Engine (``TRACE'') and municipal securities
reported to the Municipal Securities Rulemaking Board's (``MSRB'')
Electronic Municipal Market Access system. FINRA may also access data
obtained from the MSRB relating to municipal bond trading activity for
surveillance purposes in connection with trading in the Shares.
---------------------------------------------------------------------------
\34\ For a list of the current members and affiliate members of
ISG, see www.isgportal.com. The Exchange notes that not all
components of the Disclosed Portfolio for the Fund may trade on
markets that are members of ISG or with which the Exchange has in
place a comprehensive surveillance sharing agreement.
---------------------------------------------------------------------------
III. Discussion and Commission's Findings
After careful review, the Commission finds that the Exchange's
proposal to list and trade the Shares, as modified by Amendment No. 1,
is consistent with the Act and the rules and regulations thereunder
applicable to a national securities exchange.\35\ In particular, the
Commission finds that the proposed rule change, as modified by
Amendment No. 1, is consistent with Section 6(b)(5) of the Act,\36\
which requires, among other things, that the Exchange's rules be
designed to prevent fraudulent and manipulative acts and practices, 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.
---------------------------------------------------------------------------
\35\ In approving this proposed rule change, the Commission
notes that it has considered the proposed rule's impact on
efficiency, competition, and capital formation. See 15 U.S.C.
78c(f).
\36\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------
As noted above, the Fund may hold up to 100% Inflation Swaps and
Other Derivatives \37\ in a manner that may not comply with the generic
listing requirements in Rules 14.11(i)(4)(C)(iv)(a),
14.11(i)(4)(C)(iv)(b), and 14.11(i)(4)(C)(v).\38\ The Exchange states
that the Fund will only use those derivatives included in the defined
term Inflation Hedging Instruments and Other Derivatives in order to
attempt to mitigate the inflation risk of the U.S. dollar-denominated
bonds to which the Fund will have exposure. The Exchange states that
the Fund's use of derivative instruments will be collateralized. In
addition, the Exchange represents that the Shares of the Fund will
comply with all other requirements applicable to Managed Fund Shares
including, but not limited to, requirements relating to the
dissemination of key information such as the Disclosed Portfolio, NAV,
IIV, rules governing the trading of equity securities, trading hours,
trading halts, surveillance, firewalls, and the information circular.
---------------------------------------------------------------------------
\37\ The Exchange states that the Fund's investments, including
derivative instruments will be made in accordance with the 1940 Act
and consistent with the Fund's investment objective and policies. To
mitigate leveraging risk, the Fund will segregate or earmark liquid
assets determined to be liquid by the Adviser in accordance with
procedures established by the Trust's Board and in accordance with
the 1940 Act to cover its obligations under derivative instruments.
\38\ The Commission notes that it has previously approved other
proposals to list and trade series of Managed Fund Shares based on a
portfolio containing securities and instruments substantially
similar to Bonds, Inflation Hedging Instruments, and Other
Derivatives. See, e.g., Securities Exchange Act Release Nos. 76719
(December 21, 2015), 80 FR 80859 (December 28, 2015) (NYSEArca-2015-
73) (order approving listing and trading of the Guggenheim Total
Return ETF) and 77522 (April 5, 2016), 81 FR 21420 (April 11, 2016)
(NYSEArca-2015-125) (order approving listing and trading of the
RiverFront Dynamic Unconstrained Income ETF and RiverFront Dynamic
Core Income ETF).
---------------------------------------------------------------------------
The Exchange states that the Fund's Inflation Swaps and Other
Derivatives will not meet the generic listing requirement that at least
90% of the weight of the listed derivatives portion of the portfolio be
in listed derivatives for which the Exchange may obtain information via
ISG from other members or affiliates of the ISG or for which the
principal market is a market with which the Exchange has a
comprehensive
[[Page 6030]]
surveillance sharing agreement. The Exchange represents that its
surveillance procedures are adequate to properly monitor the trading of
the Shares on the Exchange during all trading sessions and to deter and
detect violations of Exchange rules and the applicable federal
securities laws. The Exchange also represents that all of the listed
instruments that would not meet this requirement would nevertheless
have a primary market that is a swap execution facility that is
registered with and under the regulatory oversight of the CFTC.\39\
---------------------------------------------------------------------------
\39\ See supra note 28.
---------------------------------------------------------------------------
The Exchange states that the Fund's investments in Inflation Swaps
and Other Derivatives will not meet the generic listing requirement
that the aggregate gross notional value of listed derivatives based on
any five or fewer underlying reference assets shall not exceed 65% of
the weight of the portfolio and that the aggregate gross notional value
of listed derivatives based on any single underlying reference asset
not exceed 30% of the weight of the portfolio. The Exchange states that
it believes the liquidity in the Treasury futures, Eurodollar futures,
and TIPS markets mitigates manipulation concerns. The Exchange further
believes that for listed swaps, including credit default swaps,
interest rate swaps, and Inflation Swaps, the price transparency and
surveillance performed by the applicable swap execution facility would
similarly act to mitigate the risk of manipulation of the Shares. The
Exchange also states that it believes that the size of the inflation
swaps market, which would include all of the Inflation Swaps that the
Fund intends to invest in, also mitigates manipulation concerns
relating to both listed and OTC Inflation Swaps held by the Fund.
The Exchange states that the Fund's holdings in OTC derivatives
will exceed 20% of the weight of the portfolio and, therefore, not meet
the generic listing requirements. The Exchange states that the Fund
will attempt to limit counterparty risk in non-cleared OTC swaps and
OTC Inflation Swaps and interest rate swaps by entering into such
contracts only with counterparties the Adviser believes are
creditworthy and by limiting the Fund's exposure to each counterparty,
and that the Adviser will monitor the creditworthiness of each
counterparty and the Fund's exposure to each counterparty on an ongoing
basis. The Exchange states that the inflation swaps market, which would
include all of the listed and OTC Inflation Swaps that the Fund intends
to invest in, is large and liquid, which the Exchange believes
mitigates the concerns the 20% limitation is intended to address.
The Commission also finds that the proposal to list and trade the
Shares on the Exchange is consistent with Section 11A(a)(1)(C)(iii) of
the Act \40\ which sets forth Congress' 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. The Exchange
represents that the intra-day, closing and settlement prices of
exchange-traded portfolio assets, including exchange-listed Equity
Holdings, ETFs, options, and futures, will be readily available from
the securities exchanges and futures exchanges trading such securities
and futures, as the case may be, automated quotation systems, published
or other public sources, or online information services such as
Bloomberg or Reuters. Intraday price quotations on both listed and OTC
swaps, TIPS, 20% OTC Instruments, Bonds, Equity Holdings that are not
exchange-listed, and fixed income instruments are available from major
broker-dealer firms and from third-parties, which may provide prices
free with a time delay or in real-time for a paid fee. Trade price and
other information relating to municipal securities is available through
the MSRB.
---------------------------------------------------------------------------
\40\ 15 U.S.C. 78k-1(a)(1)(C)(iii).
---------------------------------------------------------------------------
In addition, the Disclosed Portfolio will be available on the
issuer's website free of charge. The Fund's website includes a form of
the prospectus for the Fund and additional information related to NAV
and other applicable quantitative information. Information regarding
market price and trading volume of the Shares will be continuously
available throughout the day on brokers' computer screens and other
electronic services. Quotation and last-sale information on the Shares
will be available through the Consolidated Tape Association.
Information regarding the previous day's closing price and trading
volume for the Shares will be published daily in the financial section
of newspapers. Quotation and last-sale information for listed options
contracts cleared by the Options Clearing Corporation will be available
via the Options Price Reporting Authority. Further, trading in the
Shares may be halted for market conditions or for reasons that, in the
view of the Exchange, make trading inadvisable. The Exchange deems the
Shares to be equity securities, thus rendering trading in the Shares
subject to the Exchange's existing rules governing the trading of
equity securities. The Exchange represents that it has appropriate
rules to facilitate trading in the Shares during all trading sessions.
The Exchange has made the following representations in support of
its proposal:
(1) Other than BZX Rules 14.11(i)(4)(C)(iv)(a),
14.11(i)(4)(C)(iv)(b), and 14.11(i)(4)(C)(v), the Fund will comply
with all other requirements on an initial and continued listing
basis for Managed Fund Shares under BZX Rule 14.11(i), including
those requirements regarding the Disclosed Portfolio and the
requirement that the Disclosed Portfolio and the NAV will be made
available to all market participants at the same time,\41\ IIV,\42\
suspension of trading or removal,\43\ trading halts,\44\
disclosure,\45\ and firewalls.\46\
---------------------------------------------------------------------------
\41\ See BZX Rules 14.11(i)(4)(A)(ii) and 14.11(i)(4)(B)(ii).
\42\ See BZX Rule 14.11(i)(4)(B)(i).
\43\ See BZX Rule 14.11(i)(4)(B)(iii).
\44\ See BZX Rule 14.11(i)(4)(B)(iv).
\45\ See BZX Rule 14.11(i)(6).
\46\ See BZX Rule 14.11(i)(7).
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(2) Trading of the Shares on the Exchange will be subject to the
Exchange's surveillance procedures for derivative products,
including Managed Fund Shares, and these procedures are adequate to
properly monitor the trading of the Shares on the Exchange during
all trading sessions and to deter and detect violations of Exchange
rules and the applicable federal securities laws.
(3) All of the ETFs, exchange-listed Equity Holdings, futures
contracts, and listed options contracts held by the Fund will trade
on markets that are a member of ISG or affiliated with a member of
ISG or with which the Exchange has in place a comprehensive
surveillance sharing agreement. Additionally, the Exchange or FINRA,
on behalf of the Exchange, are able to access, as needed, trade
information for certain fixed income instruments reported to FINRA's
TRACE and municipal securities reported to the MSRB's Electronic
Municipal Market Access system. FINRA also can access data obtained
from the MSRB relating to municipal bond trading activity for
surveillance purposes in connection with trading in the Shares. The
Exchange has a policy prohibiting the distribution of material, non-
public information by its employees.
(4) Certain of the listed Inflation Swaps, listed credit default
swaps, and listed interest rate swaps held by the Fund will trade on
markets that are a member of ISG or affiliated with a member of ISG
or with which the Exchange has in place a comprehensive surveillance
sharing agreement. The Exchange, FINRA, on behalf of the Exchange,
or both will communicate regarding trading in the Shares and in
certain of the listed Inflation Swaps, credit default swaps, and
listed interest rate swaps held by the Fund with the ISG, other
markets or entities who are members or affiliates of the ISG, or
with
[[Page 6031]]
which the Exchange has entered into a comprehensive surveillance
sharing agreement.
(5) 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 will discuss the following:
(a) The procedures for purchases and redemptions of Shares in
Creation Units (and that Shares are not individually redeemable);
(b) BZX Rule 3.7, which imposes suitability obligations on Exchange
members with respect to recommending transactions in the Shares to
customers; (c) how information regarding the IIV and the Disclosed
Portfolio is disseminated; (d) the risks involved in trading the
Shares during the Pre-Opening \47\ and After Hours Trading Sessions
\48\ when an updated IIV 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.
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\47\ The Pre-Opening Session is from 8:00 a.m. to 9:30 a.m.
Eastern Time.
\48\ The After Hours Trading Session is from 4:00 p.m. to 5:00
p.m. Eastern Time.
---------------------------------------------------------------------------
(6) The Fund's investments, including derivatives, will be
consistent with the 1940 Act and the Fund's investment objective and
policies and will not be used to enhance leverage (although certain
derivatives and other investments may result in leverage).\49\
---------------------------------------------------------------------------
\49\ See supra note 23.
---------------------------------------------------------------------------
(7) The Fund's investments will not be used to seek performance
that is the multiple or inverse multiple (i.e., 2Xs and 3Xs) of the
Fund's primary broad-based securities benchmark index (as defined in
Form N-1A).
(8) Credit default swaps held by the Fund will be traded on a
U.S. Swap Execution Facility registered with the CFTC. At least 90%
of the Fund's net assets in credit default swaps will be investment-
grade at the time of purchase.
(9) To the extent that the Fund holds listed Inflation Swaps or
interest rate swaps, all such listed Inflation Swaps and listed
interest rate swaps held by the Fund will be traded on a U.S. Swap
Execution Facility registered with the CFTC.
(10) The Trust is required to comply with Rule 10A-3 under the
Act \50\ for the initial and continued listing of the Shares of the
Fund, and at least 100,000 Shares will be outstanding upon the
commencement of trading.
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\50\ See 17 CFR 240.10A-3.
The Exchange represents that all statements and representations
made in this filing regarding the description of the portfolio or
reference assets, limitations on portfolio holdings or reference
assets, dissemination and availability of index, reference asset, and
intraday indicative values, and the applicability of Exchange rules
specified in this filing shall constitute continued listing
requirements for the Fund. In addition, the issuer has represented to
the Exchange that it will advise the Exchange of any failure by the
Fund or the Shares to comply with the continued listing requirements,
and, pursuant to its obligations under Section 19(g)(1) of the Act, the
Exchange will surveil for compliance with the continued listing
requirements. If the Fund or the Shares are not in compliance with the
applicable listing requirements, the Exchange will commence delisting
procedures under BZX Rule 14.12.
This approval order is based on all of the Exchange's
representations and descriptions of the Shares and the Fund, including
those set forth above and in Amendment No. 1 to the proposed rule
change. Except as described herein, the Commission notes that the
Shares must comply with all applicable requirements of BZX Rule
14.11(i) 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 No. 1, is consistent with Section
11A(a)(1)(C)(iii) of the Act \51\ and Section 6(b)(5) of the Act \52\
and the rules and regulations thereunder applicable to a national
securities exchange.
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\51\ 15 U.S.C. 78k-1(a)(1)(C)(iii).
\52\ 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
Act,\53\ that the proposed rule change (SR-CboeBZX-2018-077), as
modified by Amendment No. 1, be, and it hereby is, approved.
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\53\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\54\
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\54\ 17 CFR 200.30-3(a)(12).
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Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019-03175 Filed 2-22-19; 8:45 am]
BILLING CODE 8011-01-P