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Ropes & Gray’s Investment Management Update October-November 2019

The following summarizes recent legal developments of note affecting the mutual fund/investment management industry

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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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