共同基金转ETF：操作考虑

Mutual Fund to ETF Conversion Task Force Contents 1Introduction 3Mutual Fund to ETF Conversion Types3Initial Decisions3Associated Costs4Operational Considerations for Asset Managers6Conversion Processing Considerations: Activities with Industry Partners 9APPENDIX: Mutual Fund to ETF Conversion Preparation Checklist Mutual Fund to ETF Conversion:Operational Considerations Introduction Beginning in 2021, there has been a steadily increasing trend of mutual funds converting to ETFs.Some key differentiators between mutual funds and ETFs are how investors purchase and sellshares, and how the funds themselves purchase and sell portfolio holdings. ETFs are attractive tocertain investors, when compared to mutual funds, because they offer intra-day liquidity and provideincreased transparency on holdings information, often with lower fees. Certain ETFs can also providegreater tax efficiency to investors in taxable accounts. When compared to mutual funds, thesepotential benefits have led to increasing interest in the use of ETFs as an investment vehicle. Some asset managers have observed this increased customer interest in ETFs and have looked foropportunities to either launch new ETFs or convert an existing mutual fund offering to an ETF, thusallowing asset managers to enhance their ability to compete in the ETF marketplace. The decisionto convert a mutual fund to an ETF is driven by many considerations, including a fund’s distributionmodel, complexity, and the composition of its shareholder base. Converting a mutual fund to an ETF is a highly bespoke process. There are disparate systems used bymutual funds and ETFs for trading, clearance, settlement, and shareholder recordkeeping that mustbe coordinated to wind down (mutual fund) and start up (ETF). To receive ETF shares, mutual fundshareholders must already have, or need to establish, a brokerage arrangement prior to conversion,including all mutual fund shareholders that are directly serviced by the asset manager. A conversionby merger may also require collapsing multiple mutual fund share classes into one ETF, involvingdifferent conversion factors for each share class. Often, there are trading moratoriums in the daysleading up to the conversion that must be coordinated and may require manual implementation. In allinstances, there are few standardized processes or straight-through processing capabilities to supportthe conversion process across asset managers. In response to this challenge, the Investment Company Institute (ICI) created the Mutual Fund to ETFConversion Task Force, which comprises asset managers, intermediaries, service providers, and theDepository Trust and Clearing Corporation (DTCC), to identify the considerations relevant to planningand executing these complex transactions. Participants represent organizations serving on a variety ofICI committees involved with conversion activities. They work in the following functional areas: »Mutual Fund Transfer Agency Operations »Account set up/maintenance »Share trading/settlement »ETF Secondary Market Operations »Shareholder position set up/maintenance»Share trading »Mutual Fund/ETF fund accounting»Mutual Fund/ETF fund administration»Mutual Fund/ETF portfolio management»Mutual Fund/ETF product management»Mutual Fund/ETF legal»Mutual Fund/ETF intermediary relationship management»Mutual Fund/ETF conversion project managers»ETF authorized participants (APs)»ETF market makers The considerations document and checklist that follow are a result of numerous discussion sessionsand interviews with various stakeholders who are planning or have already completed one or moreconversions. Each mutual fund to ETF conversion event is unique and can vary depending on thecircumstances that an asset manager must independently consider while serving the interests ofshareholders. These materials are designed to assist asset managers, intermediaries, and serviceproviders in planning and implementing conversion activities. Furthermore, these materials may proveuseful in encouraging the adoption of practices that reflect thoughtful, proactive communication,application of technology, and comprehensive planning for a successful conversion event. Background Mutual Fund to ETF Conversion Types Merger/Shell Reorganization:In this scenario, the existing mutual fund is merged with a newly createdshell ETF, often under a new trust. Direct Conversion:In a direct conversion scenario, the existing mutual fund vehicle is converted into anETF with appropriate modifications to constituent documents and operations. Initial Decisions If the mutual fund offers multiple share classes, these may need to be consolidated into a single shareclass prior to, or at the time of, the conversion as ETFs do not currently offer multiple classes. Once the decision is made to convert or merge the mutual fund into an ETF, determinations may needto be made about a variety of mutual fund fees and expenses, including Rule 12b-1 fees, continge