区间基金回购时间表

ICI Broker/Dealer Advisory CommitteeInterval Funds Task Force Contents 1Introduction 2Activities Prior to the Repurchase Pricing Date2Shareholder Mailing2Task Lists 4Repurchase Request Deadline and Repurchase Pricing Date 5Post Repurchase Request Deadline and Repurchase Pricing Date Activities 6Proration Determination7Communication Considerations7Confirmation and Payment Considerations 8Conclusion 9APPENDIX: Sample Repurchase Notices for Direct Accounts and Brokers10Example 1. Direct Account-Repurchase Notice Form19Example 2. Broker Repurchase Notice Form The content contained in this document is proprietary property of ICI and should not be reproduced or disseminated withoutICI’s prior consent. It is not intended to be, and should not be construed as, legal or investment advice. Each firm should makeindependent decisions, if any, based on the information in this document and other appropriate considerations. Interval Fund Repurchase Timeline Introduction Through a series of white papers,1the ICI Broker/Dealer Advisory Committee’s (BDAC) Interval FundsTask Force (Task Force) has educated stakeholders about the unique operating needs and requirementsof interval funds. While most interval funds are continuously offered, the fund may only authorizerepurchase of its shares a few times each year. These repurchase periods operate within the guidelinesfound in Securities and Exchange Commission (SEC) Rule 23c-3 of the Investment Company Act of 1940. Each repurchase period is governed by a repurchase offer, with specific terminology used to define thedetails of the offer, key milestones, and communication to shareholders: »Repurchase Offeris the fund’s offer to repurchase a portion of its shares.»Repurchase Offer Amountis the maximum percent of shares outstanding on the repurchaserequest deadline that the fund intends to repurchase through the related repurchase offer.»Repurchase Payment Deadlineis the date by which the fund must pay the proceeds of sharerepurchase to those who tendered shares, no later than seven days after the repurchasepricing date.»Repurchase Pricing Dateis the date on which the net asset value (NAV) associated with therepurchase is determined. This must occur either concurrent with or within 14 days of a repurchaserequest deadline, as specified in the repurchase offer.»Repurchase Requestis the affirmative response to a repurchase offer.»Repurchase Request Deadlineis the date by which the fund must receive requests–original,modified, or to withdraw previously submitted repurchase requests–for inclusion in therepurchase offer. The Task Force prepared this document to highlight many of the operational activities completedby the interval fund sponsor, its administrator, and transfer agent (TA) for each repurchase offer. Thesample timeline is provided to show these activities in a typical sequence. However, an interval fundmakes independent business decisions on how it manages the repurchase offer, including durationand milestone dates. Decisions must be compliant with Rule 23c-3, the fund’s Form N-23c-3 filing, andsupporting shareholder notifications filed with the SEC for the repurchase offer in question. Activities Prior to the Repurchase Pricing Date The following points outline activities that may be initiated up to 42 days prior to the RepurchasePricing Date. According to Interval Funds Task Force members, typically these activities beginapproximately 30 days prior. Shareholder Mailing »The Interval Fund Sponsor (i.e., the asset manager offering the Interval Fund and referred to asSponsor in this document) will generate the repurchase offer notices and provide them to FundAdministration/TA. The notice will indicate the applicable timeline and milestone dates and mayinclude various disclosures and reminders, such as the potential for proration and the relatedimpact upon payment. (Examples of repurchase offer notices can be found in the Appendix of thisdocument.) »Fund Administration will complete the mailing to all direct shareholders and intermediaries thathave a selling group agreement to offer the interval fund and confirm execution of the mailing tothe Sponsor and service providers (e.g., print mail or fulfillment agents who engage with dealers).The SEC requires mailings to be completed between 21 and 42 days prior to the RepurchaseRequest Deadline. »Fund Administration or the Sponsor coordinates with the service provider to initiate the backoffice and intermediary-specific notifications. Task Lists Initial Tasks, outlined below, often start as early as 30 days prior to the Repurchase Pricing Date: »The Sponsor, Fund Administration, Fund Accounting, and the TA begin working through thetask list.»Fund Administration (or the TA, depending on the Sponsor’s support model) generallycoordinates a Repurchase Event kickoff meeting, including the Sponsor and additionalcontributors. The meeting will typically review the following: »Repurchase Processing Date, which will ofte