Toroso Investments, LLC and Tidal ETF Trust, 6186-6188 [2019-03312]
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6186
Federal Register / Vol. 84, No. 38 / Tuesday, February 26, 2019 / Notices
Units in kind and that are based on
certain Underlying Indexes that include
foreign securities, applicants request
relief from the requirement imposed by
section 22(e) in order to allow such
Funds to pay redemption proceeds
within fifteen calendar days following
the tender of Creation Units for
redemption. Applicants assert that the
requested relief would not be
inconsistent with the spirit and intent of
section 22(e) to prevent unreasonable,
undisclosed or unforeseen delays in the
actual payment of redemption proceeds.
7. Applicants request an exemption to
permit Funds of Funds to acquire Fund
shares beyond the limits of section
12(d)(1)(A) of the Act; and the Funds,
and any principal underwriter for the
Funds, and/or any broker or dealer
registered under the Exchange Act, to
sell shares to Funds of Funds beyond
the limits of section 12(d)(1)(B) of the
Act. The application’s terms and
conditions are designed to, among other
things, help prevent any potential (i)
undue influence over a Fund through
control or voting power, or in
connection with certain services,
transactions, and underwritings, (ii)
excessive layering of fees, and (iii)
overly complex fund structures, which
are the concerns underlying the limits
in sections 12(d)(1)(A) and (B) of the
Act.
8. Applicants request an exemption
from sections 17(a)(1) and 17(a)(2) of the
Act to permit persons that are Affiliated
Persons, or Second-Tier Affiliates, of the
Funds, solely by virtue of certain
ownership interests, to effectuate
purchases and redemptions in-kind. The
deposit procedures for in-kind
purchases of Creation Units and the
redemption procedures for in-kind
redemptions of Creation Units will be
the same for all purchases and
redemptions and Deposit Instruments
and Redemption Instruments will be
valued in the same manner as those
investment positions currently held by
the Funds. Applicants also seek relief
from the prohibitions on affiliated
transactions in section 17(a) to permit a
Fund to sell its shares to and redeem its
shares from a Fund of Funds, and to
engage in the accompanying in-kind
transactions with the Fund of Funds.3
The purchase of Creation Units by a
3 The requested relief would apply to direct sales
of shares in Creation Units by a Fund to a Fund of
Funds and redemptions of those shares. Applicants
are not seeking relief from section 17(a) for, and the
requested relief will not apply to, transactions
where a Fund could be deemed an Affiliated
Person, or a Second-Tier Affiliate, of a Fund of
Funds because an Adviser or an entity controlling,
controlled by or under common control with an
Adviser provides investment advisory services to
that Fund of Funds.
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16:24 Feb 25, 2019
Jkt 247001
Fund of Funds directly from a Fund will
be accomplished in accordance with the
policies of the Fund of Funds and will
be based on the NAVs of the Funds.
9. Section 6(c) of the Act permits the
Commission to exempt any persons or
transactions from any provision of the
Act if such exemption is necessary or
appropriate in the public interest and
consistent with the protection of
investors and the purposes fairly
intended by the policy and provisions of
the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities, or transactions, from
any provision of section 12(d)(1) if the
exemption is consistent with the public
interest and the protection of investors.
Section 17(b) of the Act authorizes the
Commission to grant an order
permitting a transaction otherwise
prohibited by section 17(a) if it finds
that (a) the terms of the proposed
transaction are fair and reasonable and
do not involve overreaching on the part
of any person concerned; (b) the
proposed transaction is consistent with
the policies of each registered
investment company involved; and (c)
the proposed transaction is consistent
with the general purposes of the Act.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019–03310 Filed 2–25–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
33378; 812–14939]
Toroso Investments, LLC and Tidal
ETF Trust
February 21, 2019
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice.
AGENCY:
Notice of an application for an order
under section 6(c) of the Investment
Company Act of 1940 (the ‘‘Act’’) for an
exemption from sections 2(a)(32),
5(a)(1), 22(d), and 22(e) of the Act and
rule 22c–1 under the Act, under
sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and
17(a)(2) of the Act, and under section
12(d)(1)(J) for an exemption from
sections 12(d)(1)(A) and 12(d)(1)(B) of
the Act. The requested order would
permit (a) index-based series of certain
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open-end management investment
companies (‘‘Funds’’) to issue shares
redeemable in large aggregations
(‘‘Creation Units’’); (b) secondary market
transactions in Fund shares to occur at
negotiated market prices rather than at
net asset value (‘‘NAV’’); (c) certain
Funds to pay redemption proceeds,
under certain circumstances, more than
seven days after the tender of shares for
redemption; (d) certain affiliated
persons of a Fund to deposit securities
into, and receive securities from, the
Fund in connection with the purchase
and redemption of Creation Units; (e)
certain registered management
investment companies and unit
investment trusts outside of the same
group of investment companies as the
Funds (‘‘Funds of Funds’’) to acquire
shares of the Funds; and (f) certain
Funds to issue Shares in less than
Creation Unit size to investors
participating in a distribution
reinvestment program.
Applicants: Tidal ETF Trust (the
‘‘Trust’’), a Delaware statutory trust,
which will register with the
Commission as a series open-end
management investment company, and
Toroso Investments, LLC (the ‘‘Initial
Adviser’’), a Delaware limited liability
company registered as an investment
adviser under the Investment Advisers
Act of 1940.
Filing Dates: The application was
filed on August 9, 2018 and amended on
December 4, 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, Securities and
Exchange Commission, 100 F Street NE,
Washington, DC 20549–1090;
Applicants: The Trust and the Initial
Adviser, 898 N Broadway, Suite 2,
Massapequa, New York 11758.
FOR FURTHER INFORMATION CONTACT:
Benjamin Kalish, Attorney-Adviser, at
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Federal Register / Vol. 84, No. 38 / Tuesday, February 26, 2019 / Notices
(202) 551–7361, or Parisa Haghshenas,
Branch Chief, at (202) 551–6723
(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
website by searching for the file
number, or for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Summary of the Application
1. Applicants request an order that
would allow Funds to operate as index
exchange traded funds (‘‘ETFs’’).1 Fund
shares will be purchased and redeemed
at their NAV in Creation Units (other
than pursuant to a distribution
reinvestment program, as described in
the application). All orders to purchase
Creation Units and all redemption
requests will be placed by or through an
‘‘Authorized Participant,’’ which will
have signed a participant agreement
with the distributor. Shares will be
listed and traded individually on a
national securities exchange, where
share prices will be based on the current
bid/offer market. Any order granting the
requested relief would be subject to the
terms and conditions stated in the
application.
2. Each Fund will hold investment
positions selected to correspond closely
to the performance of an Underlying
Index. In the case of Self-Indexing
Funds, an affiliated person, as defined
in section 2(a)(3) of the Act (‘‘Affiliated
Person’’), or an affiliated person of an
Affiliated Person (‘‘Second-Tier
Affiliate’’), of the Trust or a Fund, of the
Adviser, of any sub-adviser to or
promoter of a Fund, or of the distributor
will compile, create, sponsor or
maintain the Underlying Index.2
1 Applicants request that the order apply to the
Initial Fund and any additional series of the Trust,
and any other existing or future open-end
management investment company or existing or
future series thereof (each, included in the term
‘‘Fund’’), each of which will operate as an ETF and
will track a specified index comprised of domestic
and/or foreign equity securities and/or domestic
and/or foreign fixed income securities (each, an
‘‘Underlying Index’’). Any Fund will (a) be advised
by the Initial Adviser or an entity controlling,
controlled by, or under common control with the
Initial Adviser (each of the foregoing and any
successor thereto, an ‘‘Adviser’’) and (b) comply
with the terms and conditions of the application.
For purposes of the requested order, a ‘‘successor’’
is limited to an entity or entities that result from
a reorganization into another jurisdiction or a
change in the type of business organization.
2 Each Self-Indexing Fund will post on its website
the identities and quantities of the investment
positions that will form the basis for the Fund’s
calculation of its NAV at the end of the day.
Applicants believe that requiring Self-Indexing
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16:24 Feb 25, 2019
Jkt 247001
3. Shares will be purchased and
redeemed in Creation Units and
generally on an in-kind basis, or issued
in less than Creation Unit size to
investors participating in a distribution
reinvestment program. Except where the
purchase or redemption will include
cash under the limited circumstances
specified in the application, purchasers
will be required to purchase Creation
Units by depositing specified
instruments (‘‘Deposit Instruments’’),
and shareholders redeeming their shares
will receive specified instruments
(‘‘Redemption Instruments’’). The
Deposit Instruments and the
Redemption Instruments will each
correspond pro rata to the positions in
the Fund’s portfolio (including cash
positions) except as specified in the
application.
4. Because shares will not be
individually redeemable, applicants
request an exemption from section
5(a)(1) and section 2(a)(32) of the Act
that would permit the Funds to register
as open-end management investment
companies and issue shares that are
redeemable in Creation Units (other
than pursuant to a distribution
reinvestment program).
5. Applicants also request an
exemption from section 22(d) of the Act
and rule 22c–1 under the Act as
secondary market trading in shares will
take place at negotiated prices, not at a
current offering price described in a
Fund’s prospectus, and not at a price
based on NAV. Applicants state that (a)
secondary market trading in shares does
not involve a Fund as a party and will
not result in dilution of an investment
in shares, and (b) to the extent different
prices exist during a given trading day,
or from day to day, such variances occur
as a result of third-party market forces,
such as supply and demand. Therefore,
applicants assert that secondary market
transactions in shares will not lead to
discrimination or preferential treatment
among purchasers. Finally, applicants
represent that share market prices will
be disciplined by arbitrage
opportunities, which should prevent
shares from trading at a material
discount or premium from NAV.
6. With respect to Funds that effect
creations and redemptions of Creation
Units in kind and that are based on
certain Underlying Indexes that include
foreign securities, applicants request
relief from the requirement imposed by
section 22(e) in order to allow such
Funds to pay redemption proceeds
within fifteen calendar days following
Funds to maintain full portfolio transparency will
help address, together with other protections,
conflicts of interest with respect to such Funds.
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6187
the tender of Creation Units for
redemption. Applicants assert that the
requested relief would not be
inconsistent with the spirit and intent of
section 22(e) to prevent unreasonable,
undisclosed or unforeseen delays in the
actual payment of redemption proceeds.
7. Applicants request an exemption to
permit Funds of Funds to acquire Fund
shares beyond the limits of section
12(d)(1)(A) of the Act; and the Funds,
and any principal underwriter for the
Funds, and/or any broker or dealer
registered under the Exchange Act, to
sell shares to Funds of Funds beyond
the limits of section 12(d)(1)(B) of the
Act. The application’s terms and
conditions are designed to, among other
things, help prevent any potential (i)
undue influence over a Fund through
control or voting power, or in
connection with certain services,
transactions, and underwritings, (ii)
excessive layering of fees, and (iii)
overly complex fund structures, which
are the concerns underlying the limits
in sections 12(d)(1)(A) and (B) of the
Act.
8. Applicants request an exemption
from sections 17(a)(1) and 17(a)(2) of the
Act to permit persons that are Affiliated
Persons, or Second Tier Affiliates, of the
Funds, solely by virtue of certain
ownership interests, to effectuate
purchases and redemptions in-kind. The
deposit procedures for in-kind
purchases of Creation Units and the
redemption procedures for in-kind
redemptions of Creation Units will be
the same for all purchases and
redemptions, and Deposit Instruments
and Redemption Instruments will be
valued in the same manner as those
investment positions currently held by
the Funds. Applicants also seek relief
from the prohibitions on affiliated
transactions in section 17(a) to permit a
Fund to sell its shares to and redeem its
shares from a Fund of Funds, and to
engage in the accompanying in-kind
transactions with the Fund of Funds.3
The purchase of Creation Units by a
Fund of Funds directly from a Fund will
be accomplished in accordance with the
policies of the Fund of Funds and will
be based on the NAVs of the Funds.
9. Section 6(c) of the Act permits the
Commission to exempt any persons or
transactions from any provision of the
3 The requested relief would apply to direct sales
of shares in Creation Units by a Fund to a Fund of
Funds and redemptions of those shares. Applicants,
moreover, are not seeking relief from section 17(a)
for, and the requested relief will not apply to,
transactions where a Fund could be deemed an
Affiliated Person, or a Second-Tier Affiliate, of a
Fund of Funds because an Adviser or an entity
controlling, controlled by or under common control
with an Adviser provides investment advisory
services to that Fund of Funds.
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6188
Federal Register / Vol. 84, No. 38 / Tuesday, February 26, 2019 / Notices
Act if such exemption is necessary or
appropriate in the public interest and
consistent with the protection of
investors and the purposes fairly
intended by the policy and provisions of
the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities, or transactions, from
any provision of section 12(d)(1) if the
exemption is consistent with the public
interest and the protection of investors.
Section 17(b) of the Act authorizes the
Commission to grant an order
permitting a transaction otherwise
prohibited by section 17(a) if it finds
that (a) the terms of the proposed
transaction are fair and reasonable and
do not involve overreaching on the part
of any person concerned; (b) the
proposed transaction is consistent with
the policies of each registered
investment company involved; and (c)
the proposed transaction is consistent
with the general purposes of the Act.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Eduardo A. Aleman,
Deputy Secretary.
BILLING CODE 8011–01–P
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
1. Purpose
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–85168; File No. SR–
NYSEAMER–2019–01]
Self-Regulatory Organizations; NYSE
American LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Amend Rule 7.31E
Relating to the Minimum Trade Size
Modifier
February 20, 2019.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that on February
11, 2019, NYSE American LLC (the
‘‘Exchange’’ or ‘‘NYSE American’’) filed
with the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
1 15
U.S.C. 78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
16:24 Feb 25, 2019
The Exchange proposes to amend
Rule 7.31E relating to the Minimum
Trade Size Modifier. The proposed rule
change is available on the Exchange’s
website at www.nyse.com, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
[FR Doc. 2019–03312 Filed 2–25–19; 8:45 am]
VerDate Sep<11>2014
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
Jkt 247001
The Exchange proposes to amend
Rule 7.31E relating to the Minimum
Trade Size (‘‘MTS’’) Modifier.
The MTS Modifier is currently
available for Limit IOC Orders,4
Midpoint-Liquidity (‘‘MPL’’) Orders,5
Tracking Orders,6 Non-Displayed
Primary Pegged Orders,7 and
Discretionary Pegged Orders.8 As such,
the MTS Modifier is currently available
only for orders that are not displayed
and do not route. On arrival, Limit IOC
4 See Rule 7.31E(b)(2)(A). In sum, a Limit Order
designated IOC is to be traded in whole or in part
on the Exchange as soon as such order is received,
and the quantity not so traded is cancelled. Id.
5 See Rule 7.31E(d)(3). In sum, an MPL Order is
a ‘‘Limit Order that is not displayed and does not
route, with a working price at the midpoint of the
PBBO.’’ Id.
6 See Rule 7.31E(d)(4). In sum, a Tracking Order
is an order to buy (sell) with a limit price that is
not displayed, does not route, must be entered in
round lots and designated Day, and will trade only
with an order to sell (buy) that is eligible to route.
7 See Rule 7.31E(h)(2). In sum, a Non-Displayed
Pegged Order is a Pegged Order to buy (sell) with
a working price that is pegged to the PBB (PBO),
with no offset allowed. All Pegged Orders are not
displayed and do not route. See Rule 7.31E(h).
8 See Rule 7.31E(h)(3). In sum, a Discretionary
Pegged Order is a Pegged Order to buy (sell) that
upon entry to the Exchange is assigned a working
price equal to the lower (higher) of the midpoint of
the PBBO (‘‘Midpoint Price’’) or the limit price of
the order. All Pegged Orders are not displayed and
do not route. See Rule 7.31E(h).
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Orders, MPL Orders, Non-Displayed
Primary Pegged Orders, and
Discretionary Pegged Orders with an
MTS Modifier will trade against contraside orders in the Exchange Book that in
the aggregate or individually, meet the
MTS.9 Once resting, MPL Orders,
Tracking Orders, Non-Displayed
Primary Pegged Orders, and
Discretionary Pegged Orders with an
MTS Modifier function similarly: If a
contra-side order does not meet the
MTS, the incoming order will not trade
with and may trade through the resting
order with the MTS Modifier. In
addition, MPL Orders, Tracking Orders,
Non-Displayed Primary Pegged Orders,
and Discretionary Pegged Orders with
an MTS Modifier will be cancelled if
such orders are traded in part or
reduced in size and the remaining
quantity is less than the MTS.
First, the Exchange proposes to
amend its rules to make MTS Modifier
functionality available for an additional
non-displayed order that does not route,
i.e., Non-Displayed Limit Orders.10 This
proposed change is based on the rules
of both the Nasdaq Stock Market LLC
(‘‘Nasdaq’’) and Investors Exchange LLC
(‘‘IEX’’), which both offer minimum
trade size functionality for orders that
are not displayed and that do not
route.11
Second, the Exchange proposes to
allow ETP Holder to elect that Limit IOC
Orders with an MTS Modifier trade on
arrival against contra-side orders in the
Exchange Book that individually meet
such order’s MTS. Rule 7.31E(i)(3)(B)
requires an ETP Holder to specify
whether an order with an MTS Modifier
would trade on arrival against contraside orders in the Exchange Book that in
the aggregate or individually meet such
order’s MTS. Currently, an ETP Holder
cannot elect that a Limit IOC Order with
an MTS Modifier trade only with
9 Tracking Orders, including Tracking Orders
with an MTS Modifier, are passive orders that do
not trade on arrival.
10 See Rule 7.31E(d)(2). In sum, a Non-Displayed
Limit Order is a Limit Order that is not displayed
and does not route. Id. The Exchange understands
that its affiliated exchanges, the New York Stock
Exchange, Inc. (‘‘NYSE’’), NYSE National, Inc.
(‘‘NYSE National’’), and NYSE Arca, Inc. (‘‘NYSE
Arca’’, together with the Exchange, NYSE National
and NYSE, the ‘‘Affiliate SROs’’) have either filed
or intend to file similar proposes rule changes with
the Commission to extend the availability of their
respective MTS Modifiers to Non-Displayed Limit
Orders. See SR–NYSE–2019–01 (filed for immediate
effectiveness on January 28, 2019) and SR–
NYSEArca–2019–03 (filed for immediate
effectiveness on January 28, 2019).
11 See Nasdaq Rule 4703(e) (Nasdaq’s ‘‘Minimum
Quantity Order’’ may not be displayed and will be
rejected if it includes an instruction to route) and
IEX Rule 11.190(b)(11)(A) (IEX’s ‘‘Minimum
Quantity Order’’ or ‘‘MQTY’’ is a non-displayed,
non-routable order’’).
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Agencies
[Federal Register Volume 84, Number 38 (Tuesday, February 26, 2019)]
[Notices]
[Pages 6186-6188]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-03312]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 33378; 812-14939]
Toroso Investments, LLC and Tidal ETF Trust
February 21, 2019
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice.
-----------------------------------------------------------------------
Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 2(a)(32), 5(a)(1), 22(d), and 22(e) of the Act and rule 22c-1
under the Act, under sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and 17(a)(2) of the Act, and under
section 12(d)(1)(J) for an exemption from sections 12(d)(1)(A) and
12(d)(1)(B) of the Act. The requested order would permit (a) index-
based series of certain open-end management investment companies
(``Funds'') to issue shares redeemable in large aggregations
(``Creation Units''); (b) secondary market transactions in Fund shares
to occur at negotiated market prices rather than at net asset value
(``NAV''); (c) certain Funds to pay redemption proceeds, under certain
circumstances, more than seven days after the tender of shares for
redemption; (d) certain affiliated persons of a Fund to deposit
securities into, and receive securities from, the Fund in connection
with the purchase and redemption of Creation Units; (e) certain
registered management investment companies and unit investment trusts
outside of the same group of investment companies as the Funds (``Funds
of Funds'') to acquire shares of the Funds; and (f) certain Funds to
issue Shares in less than Creation Unit size to investors participating
in a distribution reinvestment program.
Applicants: Tidal ETF Trust (the ``Trust''), a Delaware statutory
trust, which will register with the Commission as a series open-end
management investment company, and Toroso Investments, LLC (the
``Initial Adviser''), a Delaware limited liability company registered
as an investment adviser under the Investment Advisers Act of 1940.
Filing Dates: The application was filed on August 9, 2018 and
amended on December 4, 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, Securities and Exchange Commission, 100 F Street
NE, Washington, DC 20549-1090; Applicants: The Trust and the Initial
Adviser, 898 N Broadway, Suite 2, Massapequa, New York 11758.
FOR FURTHER INFORMATION CONTACT: Benjamin Kalish, Attorney-Adviser, at
[[Page 6187]]
(202) 551-7361, or Parisa Haghshenas, Branch Chief, at (202) 551-6723
(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 website by searching for the file number, or for an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Summary of the Application
1. Applicants request an order that would allow Funds to operate as
index exchange traded funds (``ETFs'').\1\ Fund shares will be
purchased and redeemed at their NAV in Creation Units (other than
pursuant to a distribution reinvestment program, as described in the
application). All orders to purchase Creation Units and all redemption
requests will be placed by or through an ``Authorized Participant,''
which will have signed a participant agreement with the distributor.
Shares will be listed and traded individually on a national securities
exchange, where share prices will be based on the current bid/offer
market. Any order granting the requested relief would be subject to the
terms and conditions stated in the application.
---------------------------------------------------------------------------
\1\ Applicants request that the order apply to the Initial Fund
and any additional series of the Trust, and any other existing or
future open-end management investment company or existing or future
series thereof (each, included in the term ``Fund''), each of which
will operate as an ETF and will track a specified index comprised of
domestic and/or foreign equity securities and/or domestic and/or
foreign fixed income securities (each, an ``Underlying Index''). Any
Fund will (a) be advised by the Initial Adviser or an entity
controlling, controlled by, or under common control with the Initial
Adviser (each of the foregoing and any successor thereto, an
``Adviser'') and (b) comply with the terms and conditions of the
application. For purposes of the requested order, a ``successor'' is
limited to an entity or entities that result from a reorganization
into another jurisdiction or a change in the type of business
organization.
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2. Each Fund will hold investment positions selected to correspond
closely to the performance of an Underlying Index. In the case of Self-
Indexing Funds, an affiliated person, as defined in section 2(a)(3) of
the Act (``Affiliated Person''), or an affiliated person of an
Affiliated Person (``Second-Tier Affiliate''), of the Trust or a Fund,
of the Adviser, of any sub-adviser to or promoter of a Fund, or of the
distributor will compile, create, sponsor or maintain the Underlying
Index.\2\
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\2\ Each Self-Indexing Fund will post on its website the
identities and quantities of the investment positions that will form
the basis for the Fund's calculation of its NAV at the end of the
day. Applicants believe that requiring Self-Indexing Funds to
maintain full portfolio transparency will help address, together
with other protections, conflicts of interest with respect to such
Funds.
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3. Shares will be purchased and redeemed in Creation Units and
generally on an in-kind basis, or issued in less than Creation Unit
size to investors participating in a distribution reinvestment program.
Except where the purchase or redemption will include cash under the
limited circumstances specified in the application, purchasers will be
required to purchase Creation Units by depositing specified instruments
(``Deposit Instruments''), and shareholders redeeming their shares will
receive specified instruments (``Redemption Instruments''). The Deposit
Instruments and the Redemption Instruments will each correspond pro
rata to the positions in the Fund's portfolio (including cash
positions) except as specified in the application.
4. Because shares will not be individually redeemable, applicants
request an exemption from section 5(a)(1) and section 2(a)(32) of the
Act that would permit the Funds to register as open-end management
investment companies and issue shares that are redeemable in Creation
Units (other than pursuant to a distribution reinvestment program).
5. Applicants also request an exemption from section 22(d) of the
Act and rule 22c-1 under the Act as secondary market trading in shares
will take place at negotiated prices, not at a current offering price
described in a Fund's prospectus, and not at a price based on NAV.
Applicants state that (a) secondary market trading in shares does not
involve a Fund as a party and will not result in dilution of an
investment in shares, and (b) to the extent different prices exist
during a given trading day, or from day to day, such variances occur as
a result of third-party market forces, such as supply and demand.
Therefore, applicants assert that secondary market transactions in
shares will not lead to discrimination or preferential treatment among
purchasers. Finally, applicants represent that share market prices will
be disciplined by arbitrage opportunities, which should prevent shares
from trading at a material discount or premium from NAV.
6. With respect to Funds that effect creations and redemptions of
Creation Units in kind and that are based on certain Underlying Indexes
that include foreign securities, applicants request relief from the
requirement imposed by section 22(e) in order to allow such Funds to
pay redemption proceeds within fifteen calendar days following the
tender of Creation Units for redemption. Applicants assert that the
requested relief would not be inconsistent with the spirit and intent
of section 22(e) to prevent unreasonable, undisclosed or unforeseen
delays in the actual payment of redemption proceeds.
7. Applicants request an exemption to permit Funds of Funds to
acquire Fund shares beyond the limits of section 12(d)(1)(A) of the
Act; and the Funds, and any principal underwriter for the Funds, and/or
any broker or dealer registered under the Exchange Act, to sell shares
to Funds of Funds beyond the limits of section 12(d)(1)(B) of the Act.
The application's terms and conditions are designed to, among other
things, help prevent any potential (i) undue influence over a Fund
through control or voting power, or in connection with certain
services, transactions, and underwritings, (ii) excessive layering of
fees, and (iii) overly complex fund structures, which are the concerns
underlying the limits in sections 12(d)(1)(A) and (B) of the Act.
8. Applicants request an exemption from sections 17(a)(1) and
17(a)(2) of the Act to permit persons that are Affiliated Persons, or
Second Tier Affiliates, of the Funds, solely by virtue of certain
ownership interests, to effectuate purchases and redemptions in-kind.
The deposit procedures for in-kind purchases of Creation Units and the
redemption procedures for in-kind redemptions of Creation Units will be
the same for all purchases and redemptions, and Deposit Instruments and
Redemption Instruments will be valued in the same manner as those
investment positions currently held by the Funds. Applicants also seek
relief from the prohibitions on affiliated transactions in section
17(a) to permit a Fund to sell its shares to and redeem its shares from
a Fund of Funds, and to engage in the accompanying in-kind transactions
with the Fund of Funds.\3\ The purchase of Creation Units by a Fund of
Funds directly from a Fund will be accomplished in accordance with the
policies of the Fund of Funds and will be based on the NAVs of the
Funds.
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\3\ The requested relief would apply to direct sales of shares
in Creation Units by a Fund to a Fund of Funds and redemptions of
those shares. Applicants, moreover, are not seeking relief from
section 17(a) for, and the requested relief will not apply to,
transactions where a Fund could be deemed an Affiliated Person, or a
Second-Tier Affiliate, of a Fund of Funds because an Adviser or an
entity controlling, controlled by or under common control with an
Adviser provides investment advisory services to that Fund of Funds.
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9. Section 6(c) of the Act permits the Commission to exempt any
persons or transactions from any provision of the
[[Page 6188]]
Act if such exemption is necessary or appropriate in the public
interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Section 12(d)(1)(J) of the Act provides that the Commission may exempt
any person, security, or transaction, or any class or classes of
persons, securities, or transactions, from any provision of section
12(d)(1) if the exemption is consistent with the public interest and
the protection of investors. Section 17(b) of the Act authorizes the
Commission to grant an order permitting a transaction otherwise
prohibited by section 17(a) if it finds that (a) the terms of the
proposed transaction are fair and reasonable and do not involve
overreaching on the part of any person concerned; (b) the proposed
transaction is consistent with the policies of each registered
investment company involved; and (c) the proposed transaction is
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consistent with the general purposes of the Act.
For the Commission, by the Division of Investment Management,
under delegated authority.
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019-03312 Filed 2-25-19; 8:45 am]
BILLING CODE 8011-01-P