请考虑：区间基金运营实践（pdf）

ICI Broker/Dealer Advisory CommitteeInterval Funds Task Force Copyright © 2020 Investment Company Institute. All rights reserved. The content contained in this document is proprietary property of ICI and should not be reproduced or disseminated without ICI’s priorconsent. The information contained in this document should be used solely for purposes of assisting firms in making independent andunilateral decisions relevant to their respective business operations. It is not intended to be, and should not be construed as, legal advice. Consider This: Interval Fund Operational Practices Contents 1Introduction 1Methods of Trading 2Straight-Through Processing3Integration into Back-Office Operations3Product Features3Fund Family Features Compatibility4Trading Methodology Comparison Table 5Scheduling Repurchase (and Subscription) Periods 6Consider Communicating8Repurchase/Subscription Period Communication8Repurchase/Subscription Period Communication Methods 9Trade Corrections10Intermediaries11Fund Managers 12Share Class Conversions13Intermediaries13Fund Managers 14Fund Exchanges15Intermediaries15Fund Managers 16Distribution Processing18Intermediaries18Fund Managers 19Conclusion Introduction Interval funds are continuously offered closed-end funds that redeem shares by making periodic repurchase offers(“tenders” or “redemptions”) at net asset value (NAV) in compliance with Securities and Exchange Commission (SEC)Rule 23c-3 under the 1940 Act, as amended in 1993. They differ from other closed-end funds that do not offer regularlyscheduled liquidity (shares are generally sold on a secondary market at a price that could be at a premium or discountto the NAV). Interval fund purchases resemble open-end mutual funds in that their shares typically are continuouslyoffered and priced daily.1 Interval fund offerings are growing rapidly in the mainstream market, placing stress on current industry capabilities toefficiently and effectively support interval fund operations. These headwinds are felt across the servicing environment,arising from interval funds’ unique combination of operating characteristics that do not fully align with prevailingtechnologies and related service models used for either closed- or open-end funds. Disjointed processes, manualstrategies to compensate for lack of automation, and inefficient processing models are a direct result of these factors. In June 2019, the Investment Company Institute (ICI) publishedInterval Funds: Operational Challenges and the Industry’sWay Forward.2The white paper, authored by a task force of ICI’s Broker/Dealer Advisory Committee (BDAC), summarizedoperational challenges in supporting interval funds and provided a call to action for the industry to developrecommended practices regarding common interval fund activities. Consider This: Interval Fund Operational Practicesis the task force’s response to this call to action. It expands ontopics raised in the original publication, outlining general considerations for interval fund counterparties (e.g., fundmanagers, intermediaries, and their respective service providers) to efficiently and effectively support interval fundsand fund shareholders. Each of the seven major subject areas are briefly introduced and then discussed from both anintermediary and fund perspective to highlight the importance of how counterparties must work together to achieveoptimal operational efficiencies in interval fund operations. Methods of Trading Consider this:A fund’s decision on how to receive interval fund trades may affect product distribution and thefeatures its interval funds offer to the marketplace. Intermediaries and funds often use a combination of trading methods in support of interval funds. Three of the mostcommon methods include the following: »DTCC Alternative Investment Product (AIP):Launched in 2008, the AIP is offered by Depository Trust & ClearingCorporation (DTCC) Wealth Management Services. AIP is designed primarily for use by unregistered alternativeinvestment products and other registered products that have limited liquidity or are not continuously offered. »NSCC Fund/SERV®:Created in 1986, National Securities Clearing Corporation (NSCC) Fund/SERV is the industryutility for processing open-end 1940 Act–registered funds, UCITS, and insurance product transactions. Fund/SERV facilitates high-volume, efficient processing, and automatic net money settlement for fund companies,broker-dealers, banks, trust companies, third-party administrators, and insurance companies. »“Check and Application”:This method involves paperwork submitted directly to the fund’s transfer agent, theprimary recordkeeper of shareholder accounts. Activity is delivered by mail, fax, or phone and processed bytransfer agent staff, including the opening of new accounts and all transaction processing. Each alternative has strengths and weaknesses when supporting interval fund operations. When deciding which tradingmethods to support, funds shou