WASHINGTON, DC — Following productive conversations with the U.S. Securities and Exchange Commission staff, Stradley Ronon, on behalf of Dimensional Fund Advisors, the largest active exchange-traded fund (ETF) issuer ranked by assets under management, has filed an amended application for exemptive relief to offer ETF share classes. Of the 53 applications filed, Dimensional’s original application is the longest pending application before the SEC and has served as the blueprint for many who have subsequently filed for exemptive relief.
The firm’s team representing Dimensional in its ETF share class relief application includes partners Michael Mundt, Bruce Leto and Jana Cresswell. Since 1982, Stradley Ronon has been proud to serve Dimensional on a variety of novel innovations and industry firsts, including representing Dimensional as one of the first asset managers to convert mutual funds into ETFs at scale.
“As an industry, we are at a pivotal point that could bring a vital investment structure to the broader market,” said Mundt, counsel to Dimensional and former SEC Division of Investment Management official. “We are pleased to collaborate with industry pioneers to foster innovation and bring value to investors.”
In addition, Stradley Ronon has released a data-driven report, “Making Sense of ETF Share Class Applications,” of the more than 50 ETF share class applications that are currently pending and the conditions proposed by each application.
About Stradley Ronon’s ETF Practice:
Our ETF practice provides representation to the independent directors, advisers and/or ETFs for three of the four largest ETF groups. Our ETF practitioners have been at the forefront of recent ETF regulatory developments and novel product innovation, including applications for ETF share class relief; SEC approvals of ETFs that use less transparent, active management strategies; and mutual-funds-to-ETF conversions. We also have collaborated with the Independent Directors Council to publish an update to its newly released white paper on board oversight of ETFs.
About Stradley Ronon’s Investment Management Practice:
As one of three firms to be ranked in Band 1 for registered funds nationwide by Chambers USA, Stradley Ronon maintains one of the largest registered fund practices in the United States. We represent open-end funds, closed-end funds, bank-affiliated funds, interval funds, master-feeder funds and ETFs comprising thousands of separate funds with a variety of strategies and shareholder categories, with assets under management exceeding $3.5 trillion.
We currently serve as fund counsel, independent director/trustee counsel, adviser counsel or as special counsel to many of the top 20 U.S. fund firms by assets under management, as well as a wide variety of small and midsized investment management clients. A meaningful number of our lawyers served for significant amounts of time at the SEC, and we have routinely obtained exemptive, no-action and interpretive relief for clients, having filed more than 40 exemptive applications on behalf of approximately 23 different fund complexes and advisers. We are also proud to serve the industry as one of three law firms selected by the Investment Company Institute (ICI) to advise on the modernization of the Investment Company Act of 1940 (1940 Act), and three of our partners sit on the ICI’s steering committee, which recently released its recommendations to reform the 1940 Act, “Reimagining the 1940 Act: Key Recommendations for Innovation and Investor Protection.”