Toroso Investments, LLC and Tidal ETF Trust; Notice of Application, 20933-20935 [2019-09800]
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Federal Register / Vol. 84, No. 92 / Monday, May 13, 2019 / Notices
as all other orders during Regular
Trading Hours, the proposed rule
change will have no effect on the
national best prices or trading during
Regular Trading Hours. The Exchange
also believes the proposed rule change
could increase its competitive position
outside of the United States by
providing investors with an additional
investment vehicle with respect to their
global trading strategies during times
that correspond with parts of regular
trading hours outside of the United
States.
The Exchange does not believe that
the proposed rule change to adopt an
opening auction process will impose
any burden on intramarket competition
that is not necessary or appropriate in
furtherance of the purposes of the Act,
because it will apply to orders and
quotes of all market participants in the
same manner. The same order types that
are not currently accepted prior to the
opening, and that do not participate in
the opening process, will similarly not
be accepted during the Queuing Period
or be eligible for trading during the
opening rotation.
The Exchange does not believe that
the proposed rule change to adopt an
opening auction process will impose
any burden on intermarket competition
that is not necessary or appropriate in
furtherance of the purposes of the Act,
because it is designed to open series on
the Exchange in a fair and orderly
manner. The Exchange believes an
opening auction process will enhance
the openings of series on the Exchange
by providing an opportunity for price
discovery based on then-current market
conditions. The proposed auction
process will provide an opportunity for
price discovery when a series opens
ensure there sufficient liquidity in a
series when it opens, and ensure series
open at prices consistent with thencurrent market conditions (at the
Exchange and other exchanges) rather
than extreme prices that could result in
unfavorable executions to market
participants. Additionally, as discussed
above, the proposed opening auction
process is substantially similar to the
Cboe Options opening auction
process.94
The proposed rule change to provide
the Exchange with flexibility regarding
trading hours for certain products will
not impose any burden on competition
not necessary or appropriate under the
Act, as another options exchange has
the same flexibility.95
94 See
95 See
Cboe Options Rule 6.2.
C2 Rule 6.1.
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The Exchange neither solicited nor
received comments on the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Because the foregoing proposed rule
change does not: (i) Significantly affect
the protection of investors or the public
interest; (ii) impose any significant
burden on competition; and (iii) become
operative for 30 days from the date on
which it was filed, or such shorter time
as the Commission may designate, it has
become effective pursuant to Section
19(b)(3)(A)(iii) of the Act 96 and
subparagraph (f)(6) of Rule 19b–4
thereunder.97
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
should be approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
CboeEDGX–2019–027 on the subject
line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
96 15
U.S.C. 78s(b)(3)(A)(iii).
97 17 CFR 240.19b–4(f)(6). In addition, Rule 19b–
4(f)(6)(iii) requires a self-regulatory organization to
give the Commission written notice of its intent to
file the proposed rule change, along with a brief
description and text of the proposed rule change,
at least five business days prior to the date of filing
of the proposed rule change, or such shorter time
as designated by the Commission. The Exchange
has satisfied this requirement.
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20933
All submissions should refer to File
Number SR–CboeEDGX–2019–027. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–CboeEDGX–2019–027 and
should be submitted on or before June
3, 2019.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.98
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019–09729 Filed 5–10–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
33469; 812–14996]
Toroso Investments, LLC and Tidal
ETF Trust; Notice of Application
May 8, 2019.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice.
AGENCY:
Notice of an application under section
6(c) of the Investment Company Act of
1940 (‘‘Act’’) for an exemption from
section 15(a) of the Act and rule 18f–2
98 17
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CFR 200.30–3(a)(12).
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Federal Register / Vol. 84, No. 92 / Monday, May 13, 2019 / Notices
under the Act, as well as from certain
disclosure requirements in rule 20a–1
under the Act, Item 19(a)(3) of Form N–
1A, Items 22(c)(1)(ii), 22(c)(1)(iii),
22(c)(8) and 22(c)(9) of Schedule 14A
under the Securities Exchange Act of
1934, and Sections 6–07(2)(a), (b), and
(c) of Regulation S–X (‘‘Disclosure
Requirements’’). The requested
exemption would permit an investment
adviser to hire and replace certain subadvisers without shareholder approval
and grant relief from the Disclosure
Requirements as they relate to fees paid
to the sub-advisers.
APPLICANTS: Tidal ETF Trust (the
‘‘Trust’’), a Delaware statutory trust
registered under the Act as an open-end
management investment company with
multiple series, 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 January 9, 2019.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application 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 June 3, 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 Street
NE, Washington, DC 20549–1090.
Applicants: Toroso Investments, LLC
and Tidal ETF Trust, 898 N Broadway,
Suite 2, Massapequa, New York 11758.
FOR FURTHER INFORMATION CONTACT: Jill
Corrigan, Senior Counsel, at (202) 551–
8929, 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://
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16:29 May 10, 2019
Jkt 247001
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Summary of the Application
1. The Initial Adviser is the
investment adviser to the Aware UltraShort Duration Enhanced Income ETF
(the ‘‘Initial Fund’’), a series of the
Trust, pursuant to an investment
management agreement with the Trust
(‘‘Investment Management
Agreement’’).1 Under the terms of the
Investment Management Agreement, the
Adviser, subject to the supervision of
the board of trustees of the Trust
(‘‘Board’’), will provide continuous
investment management of the assets of
each Subadvised Fund. Consistent with
the terms of the Investment
Management Agreement, the Adviser
may, subject to the approval of the
Board, delegate portfolio management
responsibilities of all or a portion of the
assets of a Subadvised Fund to one or
more Sub-Advisers.2 The Adviser will
continue to have overall responsibility
for the management and investment of
the assets of each Subadvised Fund. The
Adviser will evaluate, select, and
recommend Sub-Advisers to manage the
assets of a Subadvised Fund and will
oversee, monitor and review the SubAdvisers and their performance and
1 Applicants request relief with respect to the
Initial Fund, as well as to any future series of the
Trust and any other existing or future registered
open-end management investment company or
series thereof that, in each case, is advised by the
Initial Adviser or any entity controlling, controlled
by, or under common control with, the Initial
Adviser or its successors (each, also an ‘‘Adviser’’),
uses the multi-manager structure described in the
application, and complies with the terms and
conditions set forth in the application (each, a
‘‘Subadvised Fund’’). For purposes of the requested
order, ‘‘successor’’ is limited to an entity that
results from a reorganization into another
jurisdiction or a change in the type of business
organization. Future Subadvised Funds may be
operated as a master-feeder structure pursuant to
section 12(d)(1)(E) of the Act. In such a structure,
certain series of the Trust (each, a ‘‘Feeder Fund’’)
may invest substantially all of their assets in a
Subadvised Fund (a ‘‘Master Fund’’) pursuant to
section 12(d)(1)(E) of the Act. No Feeder Fund will
engage any sub-advisers other than through
approving the engagement of one or more of the
Master Fund’s sub-advisers.
2 As used herein, a ‘‘Sub-Adviser’’ for a
Subadvised Fund is (1) an indirect or direct
‘‘wholly owned subsidiary’’ (as such term is defined
in the Act) of the Adviser for that Subadvised Fund,
or (2) a sister company of the Adviser for that
Subadvised Fund that is an indirect or direct
‘‘wholly-owned subsidiary’’ of the same company
that, indirectly or directly, wholly owns the Adviser
(each of (1) and (2) a ‘‘Wholly-Owned Sub-Adviser’’
and collectively, the ‘‘Wholly-Owned SubAdvisers’’), or (3) not an ‘‘affiliated person’’ (as such
term is defined in section 2(a)(3) of the Act) of the
Subadvised Fund, any Feeder Fund invested in a
Master Fund, the Trust, or the Adviser, except to
the extent that an affiliation arises solely because
the Sub-Adviser serves as a sub-adviser to a
Subadvised Fund (‘‘Non-Affiliated Sub-Advisers’’).
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recommend the removal or replacement
of Sub-Advisers.
2. Applicants request an exemption to
permit the Adviser, subject to Board
approval, to hire certain Sub-Advisers
pursuant to Sub-Advisory Agreements
and materially amend existing SubAdvisory Agreements without obtaining
the shareholder approval required under
section 15(a) of the Act and rule 18f–2
under the Act.3 Applicants also seek an
exemption from the Disclosure
Requirements to permit a Subadvised
Fund to disclose (as both a dollar
amount and a percentage of the
Subadvised Fund’s net assets): (a) The
aggregate fees paid to the Adviser and
any Wholly-Owned Sub-Adviser; (b) the
aggregate fees paid to Non-Affiliated
Sub-Advisers; and (c) the fee paid to
each Affiliated Sub-Adviser
(collectively, Aggregate Fee
Disclosure’’).4
3. Applicants agree that any order
granting the requested relief will be
subject to the terms and conditions
stated in the application. Such terms
and conditions provide for, among other
safeguards, appropriate disclosure to
Subadvised Funds’ shareholders and
notification about sub-advisory changes
and enhanced Board oversight to protect
the interests of the Subadvised Funds’
shareholders.
4. Section 6(c) 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 provisions of the
Act, or any rule thereunder, if such
relief is necessary or appropriate in the
public interest and consistent with the
protection of investors and purposes
fairly intended by the policy and
provisions of the Act. Applicants
believe that the requested relief meets
this standard because, as further
explained in the application, the
Investment Management Agreement will
remain subject to shareholder approval,
while the role of the Sub-Advisers is
substantially equivalent to that of
individual portfolio managers, so that
requiring shareholder approval of SubAdvisory Agreements would impose
unnecessary delays and expenses on the
Subadvised Funds. Applicants believe
that the requested relief from the
3 The requested relief will not extend to any subadviser, other than a Wholly-Owned Sub-Adviser,
who is an affiliated person, as defined in section
2(a)(3) of the Act, of the Subadvised Fund, of any
Feeder Fund, or of the Adviser, other than by
reason of serving as a sub-adviser to one or more
of the Subadvised Funds (‘‘Affiliated SubAdviser’’).
4 For any Subadvised Fund that is a Master Fund,
the relief would also permit any Feeder Fund
invested in that Master Fund to disclose Aggregate
Fee Disclosure.
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Federal Register / Vol. 84, No. 92 / Monday, May 13, 2019 / Notices
Disclosure Requirements meets this
standard because it will improve the
Adviser’s ability to negotiate fees paid
to the Sub-Advisers that are more
advantageous for the Subadvised Funds.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Eduardo A. Aleman,
Deputy Secretary.
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–85794; File No. SR–
CboeBYX–2019–007]
Self-Regulatory Organizations; Cboe
BYX Exchange, Inc.; Notice of Filing
and Immediate Effectiveness of a
Proposed Rule Change Amending Rule
11.13 (Order Execution and Routing)
and Fee Schedule To Delete
References to TRIM2 and SWPB
Routing Options
May 7, 2019.
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Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 29,
2019, Cboe BYX Exchange, Inc.
(‘‘Exchange’’ or ‘‘BYX’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Exchange filed the
proposal as a ‘‘non-controversial’’
proposed rule change pursuant to
Section 19(b)(3)(A)(iii) of the Act 3 and
Rule 19b–4(f)(6) thereunder.4 The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
Cboe BYX Exchange, Inc. (the
‘‘Exchange’’ or ‘‘BYX’’) proposes to
amend Rule 11.13 (Order Execution and
Routing), as well as its Fee Schedule, to
delete references to the TRIM2 and
SWPB routing options. The text of the
proposed rule change is provided in
Exhibit 5.
The text of the proposed rule change
is also available on the Exchange’s
website (https://markets.cboe.com/us/
equities/regulation/rule_filings/byx/), at
the Exchange’s Office of the Secretary,
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(iii).
4 17 CFR 240.19b–4(f)(6).
2 17
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
[FR Doc. 2019–09800 Filed 5–10–19; 8:45 am]
1 15
and at the Commission’s Public
Reference Room.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Rule 11.13(b)(3)(G) (Other Routing
Strategies) to delete the TRIM2 routing
option. The Exchange also proposes to
amend its fee schedule to delete
references to the TRIM2 routing options
under fee codes BJ and C, as well as the
‘‘Routing Tier’’ under footnote 3.
Additionally, the Exchange proposes to
amend Rule 11.13(b)(3)(I) (SWP) to
delete the SWPB routing option and to
delete references to SWPB in the fee
schedule under fee code SW and under
footnote 9. The Exchange intends to
implement the proposed rule changes
on May 1, 2019.
Currently, Rule 11.13(b)(3)(G)
provides for the routing options under
which an order checks the System 5 for
available shares if so instructed by the
entering User 6 and then is sent to
destinations on the applicable System
routing table. The term ‘‘System routing
table’’ refers to the proprietary process
for determining the specific trading
venues to which the System routes
orders and the order in which it routes
them.7 Rule 11.13(b)(3)(G) currently
includes TRIM2 as one of such routing
5 The ‘‘System’’ is the Exchange’s electronic
communications and trading facility designated by
the Board through which securities orders of Users
are consolidated for ranking, execution and, when
applicable, routing away. See Exchange Rule
1.5(aa).
6 The term ‘‘User’’ is defined as ‘‘any Member or
Sponsored Participant who is authorized to obtain
access to the System pursuant to Rule 11.3.’’ See
Exchange Rule 1.5(cc).
7 The Exchange reserves the right to maintain a
different System routing table for different routing
options and to modify the System routing table at
any time without notice. See Exchange Rule
11.13(b)(3).
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20935
options.8 In addition, current fee code
BJ is yielded on orders routed to EDGA
using TRIM, TRIM2 or SLIM routing
strategy 9 and fee code C is yielded on
orders routed to BX using Destination
Specific, TRIM, TRIM2 or SLIM routing
strategy.10 Also, current footnote 3
provides for additional rebate per share
for orders yielding fee code C (thus
inclusive of a TRIM2 routing strategy) if
a Member achieves certain criteria.
Current Rule 11.13(b)(3)(I) provides
for SWP routing options. SWP is a
routing option under which an order
checks the System for available
displayed shares and then is sent to
destinations on the System routing
table. SWP orders route only to
Protected Quotations and only for
displayed size. Specifically, the current
rule provides for two forms of SWP
routing, SWPA and SWPB. A SWPA
order routes to destinations on the
System routing table even if at the time
of entry there is an insufficient share
quantity in the SWPA order to fulfill the
displayed size of all Protected
Quotations, whereas an entire SWPB
order will be cancelled back to a User
immediately if at the time of entry there
is an insufficient share quantity in the
SWPB order to fulfill the displayed size
of all Protected Quotations. Moreover,
current fee code SW is yielded on orders
routed using Parallel T, SWPA or SWPB
routing strategies,11 and current
footnote 9 describes the fees charged for
orders yielding fee code SW that remove
liquidity in securities priced below
$1.00 for Parallel T, SWPA or SWPB
routed executions.
The Exchange has determined that
because few Users elect the TRIM2
routing option and the SWPB routing
option, which often experiences no
usage for extended periods of time, the
current demand does not warrant the
infrastructure and ongoing maintenance
expenses required to support these
products. Therefore, the Exchange now
proposes to delete TRIM2 as a routing
option under Rule 11.13(b)(3)(G)(v) and
SWPB as a routing option under Rule
11.13(b)(3)(I). The Exchange proposes to
amend the Rule formatting accordingly,
changing current subparagraph
(b)(3)(G)(vi) to subparagraph
11.13(b)(3)(G)(v). The Exchange also
proposes to amend its fee schedule to
delete references to the TRIM2 routing
option under fee codes BJ and C, as well
8 TRIM2 routing strategy currently sends orders
to: BYX + DRT + BX + EDGA. See also note 3.
9 Orders that yield fee code BJ receive a rebate of
$0.0024 per share.
10 Orders that yield fee code C receive a rebate of
$0.0010 per share.
11 Orders that yield fee code SW receive a
discounted fee of $0.0033 per share.
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Agencies
[Federal Register Volume 84, Number 92 (Monday, May 13, 2019)]
[Notices]
[Pages 20933-20935]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-09800]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 33469; 812-14996]
Toroso Investments, LLC and Tidal ETF Trust; Notice of
Application
May 8, 2019.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice.
-----------------------------------------------------------------------
Notice of an application under section 6(c) of the Investment
Company Act of 1940 (``Act'') for an exemption from section 15(a) of
the Act and rule 18f-2
[[Page 20934]]
under the Act, as well as from certain disclosure requirements in rule
20a-1 under the Act, Item 19(a)(3) of Form N-1A, Items 22(c)(1)(ii),
22(c)(1)(iii), 22(c)(8) and 22(c)(9) of Schedule 14A under the
Securities Exchange Act of 1934, and Sections 6-07(2)(a), (b), and (c)
of Regulation S-X (``Disclosure Requirements''). The requested
exemption would permit an investment adviser to hire and replace
certain sub-advisers without shareholder approval and grant relief from
the Disclosure Requirements as they relate to fees paid to the sub-
advisers.
Applicants: Tidal ETF Trust (the ``Trust''), a Delaware statutory trust
registered under the Act as an open-end management investment company
with multiple series, 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 January 9, 2019.
Hearing or Notification of Hearing: An order granting the application
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 June 3, 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
Street NE, Washington, DC 20549-1090. Applicants: Toroso Investments,
LLC and Tidal ETF Trust, 898 N Broadway, Suite 2, Massapequa, New York
11758.
FOR FURTHER INFORMATION CONTACT: Jill Corrigan, Senior Counsel, at
(202) 551-8929, 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. The Initial Adviser is the investment adviser to the Aware
Ultra-Short Duration Enhanced Income ETF (the ``Initial Fund''), a
series of the Trust, pursuant to an investment management agreement
with the Trust (``Investment Management Agreement'').\1\ Under the
terms of the Investment Management Agreement, the Adviser, subject to
the supervision of the board of trustees of the Trust (``Board''), will
provide continuous investment management of the assets of each
Subadvised Fund. Consistent with the terms of the Investment Management
Agreement, the Adviser may, subject to the approval of the Board,
delegate portfolio management responsibilities of all or a portion of
the assets of a Subadvised Fund to one or more Sub-Advisers.\2\ The
Adviser will continue to have overall responsibility for the management
and investment of the assets of each Subadvised Fund. The Adviser will
evaluate, select, and recommend Sub-Advisers to manage the assets of a
Subadvised Fund and will oversee, monitor and review the Sub-Advisers
and their performance and recommend the removal or replacement of Sub-
Advisers.
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\1\ Applicants request relief with respect to the Initial Fund,
as well as to any future series of the Trust and any other existing
or future registered open-end management investment company or
series thereof that, in each case, is advised by the Initial Adviser
or any entity controlling, controlled by, or under common control
with, the Initial Adviser or its successors (each, also an
``Adviser''), uses the multi-manager structure described in the
application, and complies with the terms and conditions set forth in
the application (each, a ``Subadvised Fund''). For purposes of the
requested order, ``successor'' is limited to an entity that results
from a reorganization into another jurisdiction or a change in the
type of business organization. Future Subadvised Funds may be
operated as a master-feeder structure pursuant to section
12(d)(1)(E) of the Act. In such a structure, certain series of the
Trust (each, a ``Feeder Fund'') may invest substantially all of
their assets in a Subadvised Fund (a ``Master Fund'') pursuant to
section 12(d)(1)(E) of the Act. No Feeder Fund will engage any sub-
advisers other than through approving the engagement of one or more
of the Master Fund's sub-advisers.
\2\ As used herein, a ``Sub-Adviser'' for a Subadvised Fund is
(1) an indirect or direct ``wholly owned subsidiary'' (as such term
is defined in the Act) of the Adviser for that Subadvised Fund, or
(2) a sister company of the Adviser for that Subadvised Fund that is
an indirect or direct ``wholly-owned subsidiary'' of the same
company that, indirectly or directly, wholly owns the Adviser (each
of (1) and (2) a ``Wholly-Owned Sub-Adviser'' and collectively, the
``Wholly-Owned Sub-Advisers''), or (3) not an ``affiliated person''
(as such term is defined in section 2(a)(3) of the Act) of the
Subadvised Fund, any Feeder Fund invested in a Master Fund, the
Trust, or the Adviser, except to the extent that an affiliation
arises solely because the Sub-Adviser serves as a sub-adviser to a
Subadvised Fund (``Non-Affiliated Sub-Advisers'').
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2. Applicants request an exemption to permit the Adviser, subject
to Board approval, to hire certain Sub-Advisers pursuant to Sub-
Advisory Agreements and materially amend existing Sub-Advisory
Agreements without obtaining the shareholder approval required under
section 15(a) of the Act and rule 18f-2 under the Act.\3\ Applicants
also seek an exemption from the Disclosure Requirements to permit a
Subadvised Fund to disclose (as both a dollar amount and a percentage
of the Subadvised Fund's net assets): (a) The aggregate fees paid to
the Adviser and any Wholly-Owned Sub-Adviser; (b) the aggregate fees
paid to Non-Affiliated Sub-Advisers; and (c) the fee paid to each
Affiliated Sub-Adviser (collectively, Aggregate Fee Disclosure'').\4\
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\3\ The requested relief will not extend to any sub-adviser,
other than a Wholly-Owned Sub-Adviser, who is an affiliated person,
as defined in section 2(a)(3) of the Act, of the Subadvised Fund, of
any Feeder Fund, or of the Adviser, other than by reason of serving
as a sub-adviser to one or more of the Subadvised Funds
(``Affiliated Sub-Adviser'').
\4\ For any Subadvised Fund that is a Master Fund, the relief
would also permit any Feeder Fund invested in that Master Fund to
disclose Aggregate Fee Disclosure.
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3. Applicants agree that any order granting the requested relief
will be subject to the terms and conditions stated in the application.
Such terms and conditions provide for, among other safeguards,
appropriate disclosure to Subadvised Funds' shareholders and
notification about sub-advisory changes and enhanced Board oversight to
protect the interests of the Subadvised Funds' shareholders.
4. Section 6(c) 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 provisions of the Act, or
any rule thereunder, if such relief is necessary or appropriate in the
public interest and consistent with the protection of investors and
purposes fairly intended by the policy and provisions of the Act.
Applicants believe that the requested relief meets this standard
because, as further explained in the application, the Investment
Management Agreement will remain subject to shareholder approval, while
the role of the Sub-Advisers is substantially equivalent to that of
individual portfolio managers, so that requiring shareholder approval
of Sub-Advisory Agreements would impose unnecessary delays and expenses
on the Subadvised Funds. Applicants believe that the requested relief
from the
[[Page 20935]]
Disclosure Requirements meets this standard because it will improve the
Adviser's ability to negotiate fees paid to the Sub-Advisers that are
more advantageous for the Subadvised Funds.
For the Commission, by the Division of Investment Management,
under delegated authority.
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019-09800 Filed 5-10-19; 8:45 am]
BILLING CODE 8011-01-P