区间基金：运营挑战和行业前进之路（pdf）

ICI Broker/Dealer Advisory CommitteeInterval Funds Task Force The content contained in this document is proprietary property of ICI and should not be reproduced or disseminated withoutICI’s prior consent. The information contained in this document should be used solely for purposes of assisting firms in makingindependent and unilateral decisions relevant to their respective business operations. It is not intended to be, and should notbe construed as, legal advice. Interval Funds: Operational Challenges and theIndustry’s Way Forward Contents 10Operational Risks and Challenges 10Platform Registration12Trade Calendaring and Warehousing14Cash Flow Reporting and Prenotification15Proration17Trade Corrections18Dividends18Share Classes and Conversions19Position, Transaction, and Sales Data Transparency 20Summary and Considerations 22Glossary Executive Summary The financial services industry evolves by constantly innovating products and services to meet investor needs. One ofthese innovations is closed-end “interval” funds. While first permitted as an investment product some 25 years ago,interval funds are receiving renewed attention from fund companies and advisers alike who are seeking increasedproduct and portfolio diversification while providing wider access to less-liquid, longer-term investments that typicallymake up interval fund portfolios.1 Interval funds are subject to the same challenges as other financial products—how to provide innovative productsand service them in a scalable, efficient, and investor-friendly operating environment. But interval funds, with hybridoperating attributes between open-end and closed-end funds, are currently challenged in their ability to deliver onthese desired characteristics for both interval fund investors and the industry as a whole. Interval fund offerings are growing at a rapid pace in the mainstream market, placing stress on current industrycapabilities to efficiently and effectively support interval fund operations. These headwinds are felt across theservicing environment, arising from interval funds’ unique combination of operating characteristics that do not fullyalign with prevailing technologies and related service models used for either closed- or open-end funds. Disjointedprocesses, manual strategies to compensate for lack of automation, and inefficient processing models are a directresult of these factors. With an increasing number of products and greater interest among intermediaries to expand interval fund availabilityto suitable investors, many industry participants are increasingly determined to fully understand interval fundoperational, distribution, and servicing challenges. Armed with this understanding, these same industry stakeholdersare increasingly intent on promoting and pursuing changes that improve interval fund operations and distributionfor the entire industry, to achieve better outcomes for fund companies, service providers, intermediaries, and, mostimportant, interval fund investors. 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 SEC Rule 23c-3 under the 1940 Act, asamended in 1993. They differ from other closed-end funds that do not offer regularly scheduled liquidity (shares aregenerally sold on a secondary market at a price that could be at a premium or discount to the NAV). Interval fundpurchases resemble open-end mutual funds in that their shares typically are continually offered and priced daily.2 Interval funds are one way for fund companies to create portfolios with less capital volatility and holding a greaterpercentage of less-liquid, longer-term investments, often with higher risk-return opportunities than may be readilyachieved in open-end mutual funds or exchange-traded funds (ETFs).3Fund companies that specialize in creating moreilliquid portfolio structures for hedge, private equity, or other alternative (nonregistered) funds may view registeredinterval funds as a complementary product offering for their investors. Fund companies covering both open-endand alternative investments contribute to interest in interval funds and introduce unique operational and supportconsiderations that are the focus of this paper. As of fall 2018, data from SEC filings identified roughly 60 interval funds with approximately $29 billion in assets, andInterval Fund Tracker reported a 50 percent year-over-year growth in interval fund assets under management.4Thislevel of growth is creating a significant strain on the industry’s back offices supporting interval funds. In response,the Investment Company Institute’s Broker/Dealer Advisory Committee (ICI BDAC) formed its Interval Funds Task Force,which consists of fund companies offering interval funds, intermediaries, service providers, and the Depository Trust &Clearing Corporation (DTCC)5to improve interval fund operational efficiencies a