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Upcoming Deadline for Form BE-180

The U.S. Department of Commerce, through the Bureau of Economic Analysis (the “BEA”), requires U.S. financial services providers that had financial services transactions with foreign persons in excess of $3 million during their 2019 fiscal year to file a report on Form BE-180 (a “BE-180 Filing”).

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Flash Analysis: Making Sense of the Non- and Semi-Transparent Active ETF Models

Practices: Asset Management, Investment Management

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On November 14, 2019, the SEC issued notices for four “semi-transparent” active ETF models – the T. Rowe, Fidelity, Blue Tractor, and Natixis/NYSE applications. These “semi-transparent” models noticed for approval reflect variations of a “proxy portfolio” approach, where there is some transparency into the ETF’s holdings and baskets available to authorized participants (APs) and other market participants. The enclosed contains a brief comparison of some of the principal features of the non- and semi-transparent active ETF exemptive models.

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