ETF股票类操作注意事项

October 2025 Table of Contents 3Introduction5Background:ProductDifferencesandtheExemptiveReliefProcess8PrimaryETFShareClassOperationalConsiderations3.1 Initial Considerations3.2 Intermediary Considerations3.3 Reporting Requirements3.4 Interclass Exchange Mechanics3.5 Technology and Systems Considerations3.6 Investor Experience Considerations38AdditionalConsiderations41Appendix The Investment Company Institute (ICI) is the leading association representing regulated investment funds.ICI’s mission is to strengthen the foundation of the asset management industry for the ultimate benefit of thelong-term individual investor. Its members include mutual funds, exchange-traded funds (ETFs), closed-endfunds, and unit investment trusts (UITs) in the United States, and UCITS and similar funds offered to investorsin other jurisdictions. ICI also represents its members in their capacity as investment advisers to collectiveinvestment trusts (CITs) and retail separately managed accounts (SMAs). ICI has offices in Washington DC,Brussels, and London. Copyright ©2025 by the Investment Company Institute. All rights reserved. Introduction Exchange-traded funds (ETFs) have dramatically increased in popularity, with over $12 trillion dollars in totalassets. This momentum shows no signs of slowing down, as investors are increasingly looking for ways todiversify portfolios and access this product type. With the 2023 expiration of the patent that permitted one fundsponsor to offer an ETF share class alongside open-end mutual fund1share class(es) within a portfolio, assetmanagers across the industry are considering the introduction of a dual share class structure as one way to expandinvestor choice, promote efficiency and economies of scale, and foster a more competitive marketplace. The ETF share class structure will represent a significant modernization in the asset management industry, withat least 75 asset managers having filed for exemptive relief that would allow them to offer both mutual funds andETFs as separate share classes under the same portfolio. On September 29, 2025, the Securities and ExchangeCommission (SEC or Commission) indicated its intent to grant the necessary exemptive relief by issuing a notice ofan application for an order that would permit the ETF share class structure.2In anticipation of this, assetmanagers, service providers, and intermediaries have been reviewing how to operationalize and support the dualshare class structure. This paper assumes that any SEC exemptive relief to be granted will generally align with the notice ofapplication issued by the SEC on September 29, 2025.3The Investment Company Institute (ICI) will review thepaper’s contents against any final exemptive relief granted and update the paper to reflect material differences. While the current applications seek to provide a framework to address the SEC’s initial concerns regardingbrokerage cost subsidization, tax consequences, and cash drag,4there are additional operational considerationsthat will require evaluation by an industry contemplating this structure. When compared to a mutual fund, ETFs are attractive to certain investors due to their intraday liquidity, increasedtransparency of holdings, tax efficiency, and relatively low cost. ETFs operate differently from mutual funds,and those differences become important when deciding whether to operate both share class types in the sameportfolio. Notably, ETFs and mutual funds have different operational structures, trade their shares in different ways,and are often supported by separate teams and service providers within an organization. These differences createunique operational challenges as separate portfolios, but they are magnified when adding an ETF share class to anexisting mutual fund portfolio. NOTE: Most of the exemptive applications seek to permit both an ETF share class of a mutual fund and amutual fund class of an ETF. Though many of the operational considerations are similar, this paper has beenprepared from the perspective of adding an ETF share class to an existing mutual fund. In response to these challenges, ICI formed the following working groups in April 2025 to review these topics ingreater detail, with the intent of understanding what would need to be operationally considered to launch an ETFshare class within an existing mutual fund portfolio. »Intermediary Considerations»Investor Experience Considerations»Reporting Requirements»Interclass Exchange Mechanics»Technology & System Considerations These working groups were composed of ICI members (asset managers) and their key counterparties andstakeholders in both the mutual fund and ETF ecosystems, including intermediaries, service providers, and theDepository Trust and Clearing Corporation (DTCC). Each organization is unique, with its own set of circumstances, and must make independent determinationsin considering these matters. The document that follows is the result of numerous discussions of these p