Treatment of ETF Shares as “Redeemable Securities”. Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion . This relief is again consistent with the relief that the SEC has granted to ETFs under prior exemptive orders. Are required to provide the ETF’s median bid-ask spread for its most recent fiscal year in its prospectus; or At the moment it is very hard to see the liquidity in European ETFs because the trading is done over the counter and trades do not hit the consolidated tape. At the same time, the Investment Industry Regulatory Organization of Canada (IIROC) issued guidance to the Canadian industry that is substantially similar to our Notice. Fund Prospectus Disclosure Requirements. 2) The ETF … What exemptive relief does Rule 6c-11 provide? ETF not relying on rule 6c-11: A separate ETF Facts is required for each class or series of securities of an ETF. an ETF must disclose its median bid-ask spread for the most recent thirty calendar days on its website). Some of these conditions are outlined below. In the US market, ETF product developers have tried to get round front-running concerns by asking regulators to approve the launch of ETFs with less stringent transparency requirements. The “exchange-traded fund” (ETF) is one of the key financial innovations of the modern era. Exchange Traded Fund (ETF) Disclosure. an ETF must disclose its median bid-ask spread for the most recent thirty calendar days on its website). 9. NAV per share, market price and premium or discount, each as of the end of the prior business day; ETFs are currently permitted to omit both disclosures by providing the premium/discount information required in Item 11(g)(2) on their websites. Are required to disclose only median bid-ask spread on its website. Are required to disclose only the median bid-ask spread on its website. The “exchange-traded fund” (ETF) is one of the key financial innovations of the modern era. ETFs are required to distribute portfolio gains to shareholders at year-end, which may be generated by portfolio rebalancing or the need to meet diversification requirements. SEC Adopts Rule to Allow Most ETFs to Operate without an Order (With Strings Attached), available at, SEC’s Proposed Rule 6c-11 Would Level the ETF Playing Field, available at. The Commission also adopted certain related amendments to Forms N-1A, N-8B-2, and N-CEN (collectively, the “ETF Rule” or “Rule 6c-11”). JONES DAY PRESENTS®: EU Mandatory Disclosure Rules (DAC 6) Description: Provide the exact name of the fund (e.g… On September 25, 2019, the Securities and Exchange Commission (the “Commission”) adopted new rule 6c-11 under the Investment Company Act of 1940 (the “Investment Company Act”) that will permit exchange-traded funds (“ETFs”) that satisfy certain conditions to operate without the expense and delay of obtaining an exemptive order. Requiring streamlined narrative disclosures relating to an ETF’s trading costs, including bid-ask spreads; Requiring ETFs that do not rely on Rule 6c-11 to disclose median bid-ask spread information on their websites or in their prospectus; Excluding ETFs that provide premium/discount disclosures in accordance with Rule 6c-11 from the premium and discount disclosure requirements in Form N-1A; and. ETF is in compliance with the current filing requirements imposed upon investment advisers by those states in which ETF maintains clients. Disclosure requirements for ETF issuers Considering that a continuing flow of updated information represents a fundamental requirement for the guarantee of the proper operation of the market, Borsa Italiana requires, as set out in article 2.6.2 paragraph 5 of the Rules, that issuers having instruments ETFs listed on the ETFplus market make available to Borsa Italiana the following information: The reason for this is US issuers have not produced the KID for their ETFs meaning European investors will be unable to purchase them unless they are sophisticated or high net worth individuals. The U.S. Securities and Exchange Commission (SEC) voted Wednesday morning to propose significant modifications to its mutual fund and exchange-traded fund (ETF) disclosure … Det er gratis at tilmelde sig og byde på jobs. 33646, Final Rule – Exchange Traded Funds. Addition of “Selling”. You may submit a question by email to IMOCC@sec.gov. Our article, A Regulatory Framework for Exchange-Traded Funds (forthcoming in Southern California Law Review, vol. Rule 6c-11 codifies this approach by defining an ETF to mean a registered open management company (a) that issues (and redeems) creation units to (and from) authorized participants in exchange for a basket and a cash balancing amount, if any, and (b) whose shares are listed on a national securities exchange and traded at market-determined prices. ETF trading may also have tax consequences. What conditions are required to rely on Rule 6c-11? Item 11(g)(2) currently requires an ETF to provide a table showing the number of days the market price of the ETF’s shares was greater/less than the ETF’s NAV per share (i.e. The SEC declined to adopt amendments that would have required an ETF to disclose market prices of the ETF’s shares out of concern that the information could confuse investors or amendments that would have required a comparison of an index-based ETF’s performance versus the index on which it is based because funds other than ETFs … Rule 6c-11 will exempt ETFs from the redemption requirements of Section 22(e) of the Investment Company Act, allowing ETFs to delay satisfaction of a redemption request for more than seven days in the case of certain foreign investments for which a local market holiday or extended delivery cycles of another jurisdiction make timely delivery unfeasible. ETFs that fall within the scope of Rule 6c-11 are: Rule 6c-11 does not include the following types of ETFs and these ETFs will continue to operate pursuant to their exemptive orders: All ETFs will be required to provide additional disclosures regarding ETF trading and associated costs. By contrast, daily disclosure means front-running is potentially a much bigger issue for active ETFs investing in equities. ETFs that register under the Investment Company Act normally obtain exemptions from Section 22(d) and Rule 22c-1, which prohibit selling redeemable securities at prices other than those described in the prospectus or based on the net assets value (the NAV). issues to consider when trading ETFs. Are required to comply with the bid-ask spread website disclosure requirements under rule 6c-11 (i.e. Adopts a lookback period of the ETF’s most recent fiscal year for the prospectus bid-ask spread disclosure requirement. Under the rule, certain index-based and actively managed ETFs organized as open-end investment companies under the IC Act will be exempt from certain provisions under the IC Act and thus be permitted to: 1. redeem shares in creation unit aggregations 2. have their shares purchased and sold at market prices rather than net asset value (“NAV”) 3. engage with certain affiliates in in-kind transactions 4. in limited circumstances, deliver proceeds from redemptions to authorized participants in more than seve… Specifically, it must disclose the following publicly and prominently on its website: The … To get the estimated issuer revenue from a single ETF, the AUM is multiplied by the ETF… In view of the on-going disclosure requirements … 91, no. New ETF Disclosure Requirements Along with adopting Rule 6c-11, the SEC amended Form N-1A, the form that governs disclosure in an ETF’s prospectus and Statement of Additional Information (“SAI”), to provide more ETF-specific information to investors who purchase ETF shares on an exchange. A separate ETF Facts is required for each class or series of securities of an ETF… SUMMARY OF AMENDMENTS TO FORM N-1A AND ETF WEBSITE DISCLOSURE, Committee on Foreign Investment in the United States (CFIUS), Financial Institutions Advisory & Financial Regulatory, Environmental, Social and Governance (ESG), EU General Data Protection Regulation (GDPR), Global Compliance & Anticorruption (FCPA), Special Economic Zone and Regulatory Drafting, https://www.shearman.com/perspectives/2019/09/sec-adopts-rule-to-allow-most-etfs-to-operate-without-an-order, Set detailed parameters for the construction and acceptance of custom baskets that are in the best interests of the ETF and its shareholders, including the process for any revisions to or deviations from those parameters, and. Item 27(b)(7)(iv) currently requires an ETF to include a table with premium/discount information for the five most recently completed fiscal years in its annual reports. EU Mandatory Disclosure Requirements - Update . On January 13, 2009, the Securities and Exchange Commission (SEC) expanded the disclosure requirements of registered open-end investment companies to, among other things, create a new “summary” section at the beginning of each mutual fund’s statutory prospectus that will include previously required items and new items in a standard format. Rule 6c-11 does not provide a sunset provision to limit the relief from Section 22(e) to 10 years from the rule’s effective date, as was contemplated when the rule was proposed. Requires that an ETF’s summary prospectus or summary section cross-reference the ETF’s website. Website Disclosure Requirements that Differ from the Proposal. The ETF Facts must be filed at the same time as the ETF’s prospectus and the prospectus certificate applies to the ETF Facts. On September 26, 2019, the Securities and Exchange Commission (the SEC) adopted a final rule under the Investment Company Act of 1940 (the “Investment Company Act”) that will enable most exchange-traded funds (“ETFs”) to operate without an exemptive order, subject to various conditions (“Rule 6c-11”). Obsolescence of data Structured Thoughts - News For … These types of ETFs may not rely on the rule, and will instead continue to rely on exemptive orders. The following chart summarizes some of the disclosure requirements mandated by Rule 6c-11. Eligible ETFs may begin relying on Rule 6c-11 after the effective date, which is December 23, 2019. These third party data providers indicated that the data required for the ETF Facts will be readily available and accessible at a reasonable cost. The form requirements for the ETF Facts are set out in the Amendments as Form 41-101F4. Policies and procedures maintained for ETFs that use custom baskets must: Registration Statement and Website Disclosures. AdvisorShares, an active ETF specialist, ... Precidian Investments’ ActiveShares methodology that allows active non-transparent ETFs to skirt daily full portfolio disclosure requirements. Are required to provide the ETF’s median bid-ask spread for its most recent fiscal year in its prospectus; or The SEC’s exemptive orders provided a specialized understanding of ETFs that fit their operations but varied from the otherwise strict definitions of “redeemable security” and “open-end company,” as defined in Section 2(a)(32) and Section 5(a)(1) of the Investment Company Act. The disclosure must be available each business day before the opening of regular trading on the primary listing exchange of the ETF’s shares. Eliminating disclosure relating to creation unit size and disclosures applying only to ETFs with creation unit sizes of less than 25,000 shares. Our Take Going forward, ETFs should evaluate their compliance policies, as well as disclosures in ETF … Are required to include premium and discount information required in Items 11(g)(2) and 27(b)(7)(iv) in both the prospectus and annual report, unless it chooses to comply with certain website disclosure requirements under rule 6c-11. Rule 6c-11 will require the following information to be disclosed publicly and prominently on the ETF’s website: Moves the narrative disclosures regarding trading costs to Item 6 of Form N-1A, which provides investors with information regarding the purchase and sale of fund shares. Frequently Asked Questions on Exchange Traded Funds and Listed Funds . median bid-ask spread over the most recent thirty calendar days. The chart at the end of this alert compares the rule’s disclosure requirements with existing requirements for ETFs. ETFs also are subject to specific reporting requirements and disclosure obligations relating to investment objectives, risks, expenses, and other information in their registration statements and periodic reports. 5 Flickr 6LinkedIn 7 Pinterest 8 Email Updates. On December 8, 2016, the Canadian Securities Administrators published final amendments that require exchange traded mutual funds (ETFs) to produce and file a summary disclosure document called “ETF Facts” beginning on September 1, 2017. ETFs relying on Rule 6c-11 similarly will qualify for the “registered open-end investment company” exemption in Rule 11d1-2 under the Exchange Act. The Rule requires daily website disclosure of an ETF’s median bid-ask spread calculated over the most recent 30 calendar days instead of over the ETF’s most recent fiscal year. In June 2009, FINRA issued Regulatory Notice 09-31 to remind firms of their sales practice obligations relating to leveraged and inverse exchange-traded funds (ETFs). those that rely on Rule 6c-11 and those that cannot) will be eligible for the “redeemable securities” exceptions in Rules 101(c)(4) and 102(d)(4) of Regulation M and Rule 10b-17(c) under the Exchange Act in connection with secondary market transactions in ETF shares and the creation or redemption of creation units. Rule 6c-11 provides exemptive relief from certain provisions of the Investment Company Act that are necessary for an ETF to operate. In turn, Rule 6c-11 provides ETFs that fall within its scope exemptive relief from the Investment Company Act that is commensurate with the relief granted by the SEC’s prior exemptive orders. Items 6, 11 and 27 Website Disclosure Requirements. No. Index-Based ETFs Versus Actively Managed ETFs. The value of the portfolio will fluctuate with the value of the … trading in ETFs to meet the requirements of MFDA Ru le 1.2.3 and National Instrumen t31-103 o Mutual funds of ETFs •does not require add itional proficiency o Offering ETFs directly •requires addition New MFDA Proficiency Requirements al proficiency 3. Currently, this item requires an ETF to specify the number of shares it will issue or redeem in exchange for the deposit or delivery of basket assets. In June 2009, FINRA issued Regulatory Notice 09-31 to remind firms of their sales practice obligations relating to leveraged and inverse exchange-traded funds (ETFs). Rule 6c-11 requires an ETF to comply with certain conditions designed to protect investors and to be consistent with the purposes fairly intended by the policy and provisions of the Investment Company Act. 91, no. EU Mandatory Disclosure Requirements - Update . An ETF… In addition, ETFs … Our article, A Regulatory Framework for Exchange-Traded Funds (forthcoming in Southern California Law Review, vol. General Requirements The ETF Rule would require an ETF to disclose its portfolio holdings that will form the basis for the calculation of its NAV per share as of the close of business on the prior … Adopts a lookback period of the ETF's most recent fiscal year for the prospectus bid-ask spread disclosure requirement. Premium and Discount Disclosure. Items 11 and 27 Adds a requirement to include a statement that investors may be subject to other fees not reflected in the table, such as brokerage commissions and fees to financial intermediaries. Customers should be aware that a Canadian issuer may require CBL, through its local custodian, on request and/or on a regular basis, to disclose to that company information relating to the identity of CBL customers holding any of the company’s shares in CBL. Therefore, knowing what’s under the hood is more important than ever. On August 5, 2020, the Securities and Exchange Commission (SEC) proposed to update the disclosure framework for mutual funds and ETFs. Several amendments to Form N-1A, the registration form used by open-end funds, are designed to provide an ETF’s investors with additional information regarding ETF trading and associated costs. LISTING AND DISCLOSURE RULES For Foreign Exchange Traded Funds (ETF’s) Article (1) ... To list the units of an ETF, the following requirements shall be fulfilled:- 1) The ETF is established in a foreign jurisdiction recognized by SCA and ADX. ETFs not relying on rule 6c-11: Under the proposal, the SEC is proposing to: 1 The proposal also seeks to amend the advertising rules for registered investment companies and business development companies to promote more transparent and balanced statements about investment costs. On October 24, 2019, the Federal Register published Rule 6c-11, which will become effective December 23, 2019. For each holding, the ETF must disclose the following information (as applicable): quantity of each security or other asset; and. median bid-ask spread over the most recent thirty calendar days. Report an exchange-traded fund if the value of the fund was more than $1,000 at the end of the reporting period or if more than $200 in income was received during the reporting period. ETF shares cannot be redeemed directly from the ETF. The economic significance of ETFs … But unlike mutual funds, ETF … This is a new type of ETF that is built differently from a traditional ETF. Item 11(g)(1) currently provides that an ETF may omit information required by Items 11(a)(2), (b) and (c) if the ETF issues or redeems shares in creation units of not less than 25,000 shares each. Pursuant to this exemption, an ETF must deliver foreign investments as soon as practicable, but in no event later than 15 days after the tender to the ETF. [1] Among other things, Rule 6c-11 will rescind certain exemptive orders that it issued previously to ETFs and ETF sponsors, replace those orders with a standard ETF framework and establish new disclosure requirements for ETFs that rely on the rule. The SEC proposed several amendments to the disclosures that relate to fees and risks. First, the ETF’s summary prospectus or summary section will cross-reference the ETF’s website, which will be required by the Rule to disclose an ETF’s NAV per share, market price, premium or discount, and bid-ask spread information. Estimated revenue for an ETF issuer is calculated by aggregating the estimated revenue of all the respective issuer ETFs. 5, 2018), is the first academic work to show the need for, or to offer a regulatory framework for ETFs. Are excluded from premium and discount requirements in Items 11(g)(2) and 27(b)(7)(iv). Here, we summarize the highlights of Rule 6c-11 and also summarize the new disclosure requirements that will apply to ETFs.[2]. Free ratings, analyses, holdings, benchmarks, quotes, and news. Compliance officers working with exchange-traded funds (“ETFs”) likely know that Rule 6c-11 (the “ETF Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”), and related amendments to ETF disclosure requirements (“Disclosure … Requires an ETF to provide narrative disclosure identifying specific costs associated with buying and selling ETF shares and directing investors to its website for additional information. a line graph showing ETF share premiums or discounts for the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter); that issue shares that are listed on a national securities exchange and traded at market-determined prices. Exchange Traded Products Risk Disclosure Exchange Traded Funds (ETFs) are subject to market risk, including the possible loss of principal. Review new disclosure requirements for regulatory filings and ETF websites. Requires an ETF to state that an investor may incur costs attributable to the bid-ask spread. STAY CONNECTED Trading of ETF Shares at Market-Determined Prices. Items 6(a) and (b) require a fund to (1) disclose the minimum initial or subsequent investment requirements; (2) disclose that the shares are redeemable; and (3) describe the procedures for redeeming shares. Søg efter jobs der relaterer sig til Etf disclosure requirements, eller ansæt på verdens største freelance-markedsplads med 19m+ jobs. Similarly, Rule 6c-11 includes a condition that excludes leveraged and inverse ETFs. Rule 6c-11 will exempt ETFs from the restrictions contained in sections 17(a)(1) and (a)(2) of the Investment Company Act regarding the deposit and receipt of baskets by a person who is an affiliated person of an ETF (or who is an affiliated person of such a person) solely by reason of: (i) holding with the power to vote 5% or more of an ETF’s shares; or (ii) holding with the power to vote 5% or more of any investment company that is an affiliated person of the ETF. ETF relying on rule 6c-11: Adds the term “selling” to current narrative disclosure requirements to clarify that the fees and expenses reflected in the expense table may be higher for investors if they buy, hold, and sell shares of the fund. Rule 6c-11 will require the following information to be disclosed publicly and prominently on the ETF’s website: NAV per share, market price and premium or discount, each as of the end of the prior business day; a line graph showing ETF share premiums or discounts for the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter); a table showing the number of days the ETF’s shares traded at a premium or discount during the most recently completed calendar year and the most recently completed calendar quarters since that year (or the life of the ETF, if shorter); information regarding persistent (i.e. Are required to comply with the bid-ask spread website disclosure requirements under rule 6c-11 (i.e. The amendments also introduce a new disclosure delivery regime for ETFs. more than seven consecutive trading days) premium or discount of greater than 2%; and. Learn everything about Defiance Next Gen SPAC Derived ETF (SPAK). Items 11(b) and (c) require a fund to describe the procedures used when purchasing and redeeming the fund’s shares. European retail investors looking to gain access to US ETFs will be unable to do so after the deadline for the PRIIPs key investor document (KID) requirements passes on 1 January 2020. Currently, this item requires disclosure indicating only that the table describes fees and expenses investors may pay if they buy and hold shares of the fund. By using the shearman.com site you agree to us using cookies for the purpose of data analytics. an ETF must disclose its median bid-ask spread for the most recent thirty calendar days on its website). The ETF Rule is designed to create a consistent, transparent, and efficient regulatory framework for ETFs that are organized as registered open-end management investment companies (“open-end funds”) and to facilitate greater competition and innovations among ETFs. An ETF must preserve and maintain copies of all written agreements between it (or its service provider) and an authorized participant that allow the authorized participant to purchase or redeem creation units. Following a proposal put forward by the European Commission, the new mandatory disclosure requirements were introduced as an amendment to the … an ETF must disclose its median bid-ask spread for the most recent thirty calendar days on its website). ETF Portfolio Partners, Inc. (“ETF”) is an SEC registered investment adviser with its principal place of business in the State of Kansas. ETF issuers are ranked based on their estimated revenue from their ETF business. Information is provided in our Cookie Notice under Legal Notices. 1 Twitter 2 Facebook 3RSS 4YouTube This compliance guide is divided into the following parts:[1]. The same is true for active semi-transparent exchange-traded funds (ETFs). The form requirements for the ETF Facts are set out in the Amendments as Form 41-101F4. No Specific Disclosure for Smaller Creation Units. Exchange Traded Products (ETPs), which include Exchange Traded Funds (ETFs) and Leveraged and Inverse Products (L&I Products), are one of the fastest growing investment products in the world transforming the way investors access financial markets and build investment portfolios. Item 6(c)(ii) currently requires an ETF issuing shares in creation units of less than 25,000 to disclose the information required by Items 6(a) and (b). Are required to comply with the bid-ask spread website disclosure requirements under rule 6c-11 (i.e. [2]  Read our previous alerts on this topic: © Shearman & Sterling 2021 | Attorney Advertising. The Rule requires an ETF to disclose the portfolio holdings that will form the basis for each calculation of NAV per share in a standardized format, on each business day before the opening of regular trading of the primary listing exchange of the ETF… Are required to comply with the bid-ask spread website disclosure requirements under rule 6c-11 (i.e. Understanding Inverse or Leveraged Exchange Traded Funds. Removes the requirement that an ETF specify the number of shares it will issue or redeem in exchange for the deposit or delivery of basket assets. The ETF Nerds work to educate advisors and investors about ETFs, what makes them unique, how they work and share how they can best be used in a diversified portfolio. Inverse or Leveraged Exchange Traded Funds (ETFs) are complex investment products that carry risks … EXCHANGE TRADED FUNDS (“ETF”) DISCLOSURE NOTICE This notice is provided by Citigroup Global Markets Limited, Citibank, N.A. The rule also does not include additional conditions relating to index-based ETFs with affiliated index providers (self-indexed ETFs). Items 11 and 27 information regarding persistent (i.e. [1] This guide was prepared by the staff of the U.S. Securities and Exchange Commission as a “small entity compliance guide” under Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, as amended. This definition effectively accepts ETFs as a version of “open-end” funds permitted to issue “redeemable securities” (redeemable on demand but only in connection with the creation unit process). 16. These include: These disclosure requirements apply to certain ETFs that are not included within the scope of Rule 6c-11. The proposal includes revisions to simplify the presentation of fees and expenses in the prospectus and help increase investor comprehension. In addition, the rules under the Securities Exchange Act of 1934 (the “Exchange Act”) that apply to transactions in redeemable securities issued by an open-end fund will apply to ETFs relying on Rule 6c-11. Website Disclosure Requirements that Differ from the Proposal. A related exemptive order providing relief to broker-dealers and certain other persons from certain provisions of the Securities Exchange Act and its rules for transactions involving ETF shares can be found on the Commission’s website at https://www.sec.gov/rules/exorders/2019/34-87110.pdf. As previously reported in Euro Tax Flash 369, mandatory disclosure requirements (MDR) for intermediaries and relevant taxpayers entered into force in the European Union on June 25, 2018 and must be implemented by Member States before December 31, 2019, to be applied as of July 1, 2020. ETF issuers are one, of some might say, a small group of promoters who are looking forward to the implementation of the new post-trade disclosure rules. The compliance date for the amendments to Form N-1A is December 22, 2020, one year following the effective date. ETF relying on rule 6c-11: ... Disclosure requirements, key to ESG standardization, expected to increase under a Democratic sweep Spinnaker Trust Jan 19, 2021. Following a proposal put forward by the European Commission, the new mandatory disclosure requirements were introduced as an amendment to the Directive on Administrative Cooperation in the Field of Taxation (“DAC6”) and will apply from July 1, 2020. Expense Disclosure. In light of the disclosure requirement of ongoing charges figure as set out in the Guidelines, is an SFC-authorized ETF still required to disclose the estimated total expense ratio (“TER”) of the scheme in its offering documents in accordance with paragraph 21A of the Appendix I to the UT Code? Only the rule or form itself can provide complete and definitive information regarding its requirements. Videocast: Asset management regulation in 2020 ... (ETF) Rule . ETFs relying on rule 6c-11: Consistent with the SEC’s prior exemptive orders, Rule 6c-11 will codify those same exemptions, enabling secondary market trading of ETF shares at market-determined prices. Going forward, ETFs should evaluate their compliance policies, as well as disclosures in ETF prospectuses and statements of additional information to ensure that they are appropriate when Rule 6c-11 becomes fully effective. Median bid-ask spread over the most recent thirty calendar days. Implementing new disclosure documents for the ETF industry has been a long time coming for Canada's investment community. New ETF Disclosure Requirements Along with adopting Rule 6c-11, the SEC amended Form N-1A, the form that governs disclosure in an ETF’s prospectus and Statement of Additional Information (“SAI”), to provide more ETF-specific information to investors who purchase ETF … The portfolio holdings that will form the basis for each calculation of net asset value per share. Like a mutual fund, an ETF is a pooled investment fund that offers an investor an interest in a professionally managed, diversified portfolio of investments. Specify the titles or roles of employees of the ETF’s investment adviser who are required to review each custom basket for compliance with those parameters. Adopts a lookback period of the ETF’s most recent fiscal year for the prospectus bid-ask spread disclosure requirement. You may contact the Division of Investment Management is happy to assist small entities questions! 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