Notice2025-09387

Self-Regulatory Organizations; The Nasdaq Stock Market LLC; Notice of Filing of Proposed Rule Change To Adopt Rule 5703 To Permit the Generic Listing and Trading of Multi-Class Exchange-Traded Fund Shares

Primary source

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Published
May 27, 2025

Issuing agencies

Securities and Exchange Commission

Full Text

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<title>Federal Register, Volume 90 Issue 100 (Tuesday, May 27, 2025)</title>
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[Federal Register Volume 90, Number 100 (Tuesday, May 27, 2025)]
[Notices]
[Pages 22373-22380]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-09387]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-103072; File No. SR-NASDAQ-2025-037]


Self-Regulatory Organizations; The Nasdaq Stock Market LLC; 
Notice of Filing of Proposed Rule Change To Adopt Rule 5703 To Permit 
the Generic Listing and Trading of Multi-Class Exchange-Traded Fund 
Shares

May 20, 2025.
    Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 
(``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that 
on May 6, 2025, The Nasdaq Stock Market LLC (``Nasdaq'' or 
``Exchange'') filed with the Securities and Exchange Commission 
(``SEC'' or ``Commission'') the proposed rule change as described in 
Items I and II below, which Items have been prepared by the Exchange. 
The Commission is publishing this notice to solicit comments on the 
proposed rule change from interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance 
of the Proposed Rule Change

    The Exchange proposes to adopt Rule 5703 to permit the generic 
listing and trading of Multi-Class Exchange-Traded Fund (``ETF'') 
Shares that comply with the requirements of Rule 6c-11 under the 
Investment Company Act of 1940 (the ``Investment Company Act'') and are 
eligible to operate in reliance on exemptive relief from certain 
requirements of the Investment Company Act of 1940 and the rules and 
regulations thereunder that permit the trust issuing the Multi-Class 
ETF Shares to offer an exchange-traded fund class in addition to 
classes of shares that are not exchange-traded. The Exchange is also 
proposing to make conforming changes to Rule 5615 (Exemptions from 
Certain Corporate Governance Requirements), Rule 5705(b) (Index Fund 
Shares), Rule 5735 (Managed Fund Shares), and Equity 4, Rule 4120 in 
order to accommodate the proposed listing of Multi-Class ETF Shares.
    The text of the proposed rule change is available on the Exchange's 
website at <a href="https://listingcenter.nasdaq.com/rulebook/nasdaq/rulefilings">https://listingcenter.nasdaq.com/rulebook/nasdaq/rulefilings</a>, at the principal office of the Exchange, and at the 
Commission's Public Reference Room.

II. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

    In its filing with the Commission, the Exchange included statements 
concerning the purpose of and basis for the proposed rule change and 
discussed any comments it received on the proposed rule change. The 
text of these statements may be examined at the places specified in 
Item IV below. The Exchange has prepared summaries, set forth in 
sections A, B, and C below, of the most significant aspects of such 
statements.

A. Self-Regulatory Organization's Statement of the Purpose of, and 
Statutory Basis for, the Proposed Rule Change

1. Purpose
    The Exchange proposes to adopt new Rule 5703 for the purpose of 
permitting the generic listing and trading, or trading pursuant to 
unlisted trading privileges, of Multi-Class Exchange-Traded Fund 
(``ETF'') Shares that comply with the requirements of Rule 6c-11 under 
the Investment Company Act of 1940 (the ``Investment Company Act''), 
and are eligible to operate in reliance on exemptive relief from 
certain requirements of the Investment Company Act and the rules and 
regulations thereunder that permit the trust issuing the Multi-Class 
ETF Shares to offer an exchange-traded fund class in addition to 
classes of shares that are not exchange-traded of an open-end fund.\3\ 
The Exchange is also proposing to make conforming changes to Rule 5615 
(Exemptions from Certain Corporate Governance Requirements), Rule 
5705(b) (Index Fund Shares), Rule 5735 (Managed Fund Shares), and 
Equity 4, Rule 4120 in order to accommodate the proposed listing of 
Multi-Class ETF Shares.
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    \3\ The Exchange notes that Cboe BZX Exchange, Inc. (``BZX'') 
has filed a substantially similar filing. See Securities Exchange 
Act Release No. 102594 (March 11, 2025), 90 FR 12387 (March 17, 
2025) (SR-CboeBZX-2024-112).
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    Consistent with Exchange Traded Fund Shares, Index Fund Shares, and 
Managed Fund Shares listed under the generic listing standards in Rules 
5704, 5705(b), and 5735, respectively, series of Multi-Class ETF Shares 
that comply with the requirements of Rule 6c-11 under the Investment 
Company Act, and are eligible to operate in reliance on exemptive 
relief from certain requirements of the Investment Company Act and the 
rules and regulations thereunder that permit the trust issuing the 
Multi-Class ETF Shares to offer an exchange-traded fund class in 
addition to classes of shares that are not exchange-traded of an open-
end fund would be permitted to be listed and traded on the Exchange 
without prior Commission approval order or notice of effectiveness 
pursuant to Section 19(b) of the Act.\4\
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    \4\ Rule 19b-4(e)(1) provides that the listing and trading of a 
new derivative securities product by a self-regulatory organization 
(``SRO'') is not deemed a proposed rule change, pursuant to 
paragraph (c)(1) of Rule 19b-4, if the Commission has approved, 
pursuant to Section 19(b) of the Act, the SRO's trading rules, 
procedures and listing standards for the product class that would 
include the new derivative securities product and the SRO has a 
surveillance program for the product class. As contemplated by this 
Rule 5703, the Exchange proposes new Rule 5703 to establish generic 
listing standards for Multi-Class ETFs that are permitted to operate 
in reliance on exemptive relief to Rule 6c-11 under the Investment 
Company Act that permits the trust issuing the Multi-Class ETF 
Shares to offer an exchange-traded fund class in addition to classes 
of shares that are not exchange-traded of an open-end fund. A Multi-
Class ETF listed under proposed Rule 5703 would therefore not need a 
separate proposed rule change pursuant to Rule 19b-4 before it can 
be listed and traded on the Exchange.

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[[Page 22374]]

Background
    There are numerous applications for exemptive relief for Multi-
Class ETF Shares currently before the Commission \5\ that request 
exemptive relief similar to that previously granted to other funds.\6\ 
This proposal would provide for the ``generic'' listing and/or trading 
of Multi-Class ETF Shares under proposed Rule 5703 on the Exchange 
immediately upon the Commission's applicable order granting exemptive 
relief to the outstanding applications. The Exchange submits this 
proposal only to prevent any unnecessary delay in listing additional 
Multi-Class ETF Shares generically under Rule 5703 when and if such 
requests are granted by the Commission.
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    \5\ See e.g., DFA Investment Dimensions Group Inc. and 
Dimensional Investment Group Inc., (amendment filed March 31, 2025); 
F/m Investments LLC (amendment filed April 10, 2025); Fidelity 
Hastings Street Trust and Fidelity Management & Research Company 
(amendment filed April 11, 2025); Morgan Stanley Institutional Fund 
Trust and Morgan Stanley Investment Management Inc. (amendment filed 
April 11, 2025); BlackRock Funds (amendment filed April 15, 2025); 
Guinness Atkinson Funds (amendment filed April 17, 2025); 
Metropolitan West Funds, TCW ETF Trust, and TCW Funds, Inc. 
(amendment filed April 22, 2025); and Northern Funds and Northern 
Trust Investments, Inc. (amendment filed May 2, 2025).
    \6\ See infra note 7.
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    Starting in 2000, the Commission began granting limited relief for 
The Vanguard Group, Inc. (``Vanguard'') to offer certain index-based 
open-end management investment companies with Multi-class ETF 
Shares.\7\ After this relief was granted, there was limited public 
discourse about Multi-class ETF Shares until 2019, when the prospect of 
providing blanket exemptive relief to Multi-class ETF Shares was 
addressed in the Commission's adoption of Rule 6c-11 under the 
Investment Company Act (the ``ETF Rule'').\8\ The ETF Rule permits ETFs 
that satisfy certain conditions to operate without the expense or delay 
of obtaining an exemptive order. However, the ETF Rule did not provide 
blanket exemptive relief to allow for Multi-class ETF Shares as part of 
the final rule. Instead, the Commission concluded that Multi-class ETF 
Shares should request relief through the exemptive application process 
so that the Commission may assess all relevant policy considerations in 
the context of the facts and circumstances of particular applicants. 
The Exchange adopted Rule 5704 shortly after the implementation of the 
ETF Rule and, because there were no exemptive applications before the 
Commission, did not propose to include any language comparable to what 
is being proposed herein.\9\
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    \7\ See Vanguard Index Funds, Investment Company Act Release 
Nos. 24680 (Oct. 6, 2000) (notice) and 24789 (Dec. 12, 2000) 
(order). The Commission itself, as opposed to the Commission staff 
acting under delegated authority, considered the original Vanguard 
application and determined that the relief was appropriate in the 
public interest and consistent with the protection of investors and 
the purposes fairly intended by the policy and provisions of the 
Act. In the process of granting the order, the Commission also 
considered and denied a hearing request on the original application, 
as reflected in the final Commission order. See also the Vanguard 
Group, Inc., Investment Company Act Release Nos. 26282 (Dec. 2, 
2003) (notice) and 26317 (Dec. 30, 2003) (order); Vanguard 
International Equity Index Funds, Investment Company Act Release 
Nos. 26246 (Nov. 3, 2003) (notice) and 26281 (Dec. 1, 2003) (order); 
Vanguard Bond Index Funds, Investment Company Act Release Nos. 27750 
(Mar. 9, 2007) (notice) and 27773 (April 2, 2007) (order) 
(collectively referred to as the ``Vanguard Orders'').
    \8\ See Securities Exchange Act Release No. 33-10695 (October 
24, 2019), 84 FR 57162 (the ``ETF Rule Adopting Release'').
    \9\ See Securities Exchange Act Release No. 88561 (April 3, 
2020), 85 FR 19984 (April 9, 2020) (SR-NASDAQ-2019-090).
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    As noted above, a number of applications for exemptive relief to 
permit the applicable fund to offer Multi-class ETF Shares (the 
``Applications'') have been submitted to the Commission starting in 
early 2023. In general, the Applications state that the ability of a 
fund to offer Multi-class ETF Shares, i.e., both a class of mutual fund 
shares (each such class, a ``Mutual Fund class'' and such shares 
``Mutual Fund Shares'') and ETF Shares, could be beneficial to the fund 
and to shareholders of each type of class for various reasons, 
including more efficient portfolio management, better secondary market 
trading opportunities, and cost efficiencies, among others.\10\
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    \10\ Specifically, the Applicants believe that a Mutual Fund 
class would benefit ETF class shareholders because investor cash 
flows through a Mutual Fund class can be used for efficient 
portfolio rebalancing. To the extent that cash flows come into a 
fund through a Mutual Fund class, a portfolio manager may be able to 
deploy that cash strategically to rebalance the portfolio. Second, 
cash flows through a Mutual Fund class may allow for greater 
creation basket flexibility for creations and redemptions through 
the ETF class, which could promote arbitrage efficiency and smaller 
spreads on the trading of ETF Shares in the secondary market. With 
respect to existing funds, ETF classes would permit investors that 
prefer the ETF structure to gain access to established funds' 
investment strategies. Additionally, the establishment of an ETF 
class as part of an existing fund could lead to cost efficiencies. 
Specifically, in terms of fund expenses, an ETF class could have 
initial and ongoing advantages for its shareholders, where 
shareholders of an ETF class of a fund that already has substantial 
assets could immediately benefit from economies of scale. Finally, 
the tax-free conversion of shares from the Mutual Fund class to the 
ETF class may accelerate the development of an ETF shareholder base. 
Subsequent secondary market transactions by the ETF class 
shareholders could generate greater trading volume, resulting in 
lower trading spreads and/or premiums or discounts in the market 
prices of the ETF Shares to the benefit of ETF shareholders. The 
Applicants also believe that an ETF class would benefit Mutual Fund 
class shareholders because in-kind transactions through the ETF 
class may contribute to lower portfolio transaction costs and 
greater tax efficiency. Additionally, the conversion feature could 
allow Mutual Fund shareholders to convert Mutual Fund Shares for ETF 
Shares without adverse consequences to the Fund by allowing Mutual 
Fund shareholders to convert their shares into the ETF class of the 
same fund rather than redeeming their Mutual Fund Shares and buying 
shares of another ETF. In doing so, the converting shareholder could 
save on transaction costs and potential tax consequences that may 
otherwise be incurred in redeeming their existing shares and buying 
separate ETF Shares. The ETF class would also represent an 
additional distribution channel for a fund that could lead to 
additional asset grown and economies of scale; greater assets under 
management may lead to additional cost efficiencies and an improved 
tax profile for the fund may also assist the competitive position of 
the Fund for attracting prospective shareholders. Last, the class of 
ETF Shares could allow certain investors to engage in more frequent 
trading without disrupting the fund's portfolio.
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    While Multi-class ETF Shares could potentially be listed under 
existing Exchange Rules 5705(b) or 5735, doing so would unnecessarily 
re-introduce the burdensome quantitative portfolio requirements and 
ongoing compliance obligations associated therewith that existed before 
the adoption of Rule 6c-11 and Exchange Rule 5704.\11\ The Exchange is 
not aware of any clear policy rationale as to why those quantitative 
requirements should apply to Multi-class ETF Shares other than the 
rules are already in place. As such, listing Multi-class ETF Shares 
under these older rules would place undue burdens on both the Exchange 
and fund issuers because of the quantitative portfolio requirements 
that currently do not apply to ETFs meeting the requirements of Rule 
6c-11 and Rule 5704. Furthermore, while the Applicants generally seek 
the same exemptive relief as granted under those previous orders,\12\ 
several Applicants have proposed different conditions to the relief 
that reflect the adoption of Rule 6c-11. Therefore, the Exchange 
believes there is a reasonable relationship between the Applications 
and the proposed rule change to allow for the Commission's evaluation 
of whether the proposed rule change is consistent with the Act. The 
Exchange also acknowledges that approval of this proposed rule change 
would not necessarily result in the listing and trading of the 
additional Multi-class ETF Shares under the proposed Rule until and 
unless the necessary relief was granted by the Division of Investment 
Management, but approving this proposal would address any potential 
concerns the Commission's Division of Trading and Markets might have as 
it

[[Page 22375]]

specifically relates to the listing and trading of Multi-class ETF 
Shares under proposed Rule 5704 and would allow for a smooth launch 
process if and when such relief is granted.\13\
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    \11\ See e.g., Exchange Rules 5705(b) and 5735.
    \12\ See supra note 6.
    \13\ The Commission has in some instances historically approved 
Exchange listing rules even when no products would necessarily be 
permitted to list under those rules. Recently, the Commission 
approved Exchange proposals to list and trade shares of ether-based 
exchange-traded products (``ETPs'') prior to any such products 
having an effective registration statement. As those ether-based 
ETPs could not trade on the Exchange without an effective 
registration statement, which were separately considered by the 
Commission's division of corporate finance, the Exchange could not 
list and trade those products even with proper Exchange Rules in 
place. The Exchange believes this example illustrates the 
reasonability of the Exchange pursuing the adoption a proposed Rule 
that would not immediately result in the listing and trading of the 
applicable products thereunder. See Securities Exchange Act No. 
100224 (May 23, 2024) 89 FR 46937 (May 30, 2024) (Order Granting 
Accelerated Approval of Proposed Rule Changes, as Modified by 
Amendments Thereto, To List and Trade Shares of Ether-Based 
Exchange-Traded Products).
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Proposal
    Proposed Rule 5703(a) provides that the Exchange will consider for 
trading, whether by listing or pursuant to unlisted trading privileges, 
the shares of Multi-Class ETF Shares that meet the criteria of this 
Rule.\14\
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    \14\ To the extent that a series of Multi-Class ETF Shares does 
not satisfy one or more of the criteria in proposed Rule 5703, the 
Exchange may file a separate proposal under Section 19(b) of the Act 
in order to list such series on the Exchange. Any of the statements 
or representations in that proposal regarding the index composition, 
the description of the portfolio or reference assets, limitations on 
portfolio holdings or reference assets, dissemination and 
availability of index, reference asset, and intraday indicative 
values (as applicable), or the applicability of Exchange listing 
rules specified in any filing to list such series of Multi-Class ETF 
Shares shall constitute continued listing requirements for the 
series of Multi-Class ETF Shares. Further, in the event that a 
series of Multi-Class ETF Shares becomes listed under proposed Rule 
5703 and subsequently can no longer rely on the applicable exemptive 
relief to Rule 6c-11, such series of Multi-Class ETF Shares may be 
listed as a series of Index Fund Shares under Rule 5705(b) or 
Managed Fund Shares under Rule 5735, as applicable, as long as the 
series of Multi-Class ETF Shares meets all listing requirements 
applicable under the applicable rule.
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    Proposed Rule 5703(b) provides that the proposed rule would be 
applicable only to Multi-Class ETF Shares. Except to the extent 
inconsistent with this Rule, or unless the context otherwise requires, 
the rules and procedures of the Board of Directors shall be applicable 
to the trading on the Exchange of such securities. Multi-Class ETF 
Shares are included within the definition of ``security'' or 
``securities'' as such terms are used in the Rules of the Exchange.
    Proposed Rule 5703(b) further provides that: (1) transactions in 
Multi-Class ETF Shares will occur throughout the Exchange's trading 
hours; and (2) the Exchange will implement and maintain written 
surveillance procedures for Multi-Class ETF Shares.
    Proposed Rule 5703(c) will set forth the definitions used in the 
Rule. Specifically, proposed Rule 5703(c)(1) provides that the term 
``Multi-Class ETF Shares'' means shares of stock issued by a Multi-
Class ETF.
    Proposed Rule 5703(c)(2) provides that the term ``Multi-Class ETF'' 
means a fund that is subject to the same relief and constraints as 
exchange-traded funds under Rule 6c-11 under the Investment Company 
except that the security is issued by a trust that issues Multi-Class 
ETF Shares in addition to classes of shares of an open-end fund that 
are not exchange-traded.
    Proposed Rule 5703(c)(3) provides that the term ``Reporting 
Authority'' in respect of a particular series of Multi-Class ETF Shares 
means the Exchange, an institution, or a reporting service designated 
by the Exchange or by the exchange that lists a particular series of 
Multi-Class ETF Shares (if the Exchange is trading such series pursuant 
to unlisted trading privileges) as the official source for calculating 
and reporting information relating to such series, including, but not 
limited to, the amount of any dividend equivalent payment or cash 
distribution to holders of Multi-Class ETF Shares, net asset value, 
index or portfolio value, the current value of the portfolio of 
securities required in connection with issuance of Multi-Class ETF 
Shares, or other information relating to the issuance, redemption or 
trading of Multi-Class ETF Shares. A series of Multi-Class ETF Shares 
may have more than one Reporting Authority, each having different 
functions.
    Proposed Rule 5703(d) provides that the Exchange may approve a 
series of Multi-Class ETF Shares for listing and/or trading (including 
pursuant to unlisted trading privileges) on the Exchange pursuant to 
Rule 19b-4(e) under the Act, provided such series of Multi-Class ETF 
Shares complies with the requirements of Rule 6c-11 under the 
Investment Company Act, and is eligible to operate in reliance on 
exemptive relief from certain requirements of the Investment Company 
Act and the rules and regulations thereunder that permits the fund to 
offer Multi-Class ETF Shares, and must satisfy the requirements of this 
Rule on an initial and continued listing basis.
    Proposed Rule 5703(d)(1) provides that the requirements of 
paragraph (d) of this Rule must be satisfied by a series of Multi-Class 
ETF Shares on an initial and continued listing basis. Such securities 
must also satisfy the following criteria on an initial and, except for 
sub-paragraph (A) below, continued, listing basis. Further, proposed 
Rule 5703(d)(1) provides that: (A) for each series, the Exchange will 
establish a minimum number of Multi-Class ETF Shares required to be 
outstanding at the time of commencement of trading on the Exchange; (B) 
if an index underlying a series of Multi- Class ETF Shares is 
maintained by a broker-dealer or fund adviser, the broker-dealer or 
fund adviser shall erect and maintain a ``fire wall'' around the 
personnel who have access to information concerning changes and 
adjustments to the index and the index shall be calculated by a third 
party who is not a broker-dealer or fund adviser. If the investment 
adviser to the investment company issuing an actively managed series of 
Multi-Class ETF Shares is affiliated with a broker-dealer, such 
investment adviser shall erect and maintain a ``fire wall'' between the 
investment adviser and the broker-dealer with respect to access to 
information concerning the composition and/or changes to such Multi-
Class ETF's portfolio; and (C) any advisory committee, supervisory 
board, or similar entity that advises a Reporting Authority or that 
makes decisions on the composition, methodology, and related matters of 
an index underlying a series of Multi-Class ETF Shares, must implement 
and maintain, or be subject to, procedures designed to prevent the use 
and dissemination of material non-public information regarding the 
applicable index. For actively managed Multi-Class ETFs, personnel who 
make decisions on the portfolio composition must be subject to 
procedures designed to prevent the use and dissemination of material 
nonpublic information regarding the applicable portfolio.
    Proposed Rule 5703(d)(2) provides that each series of Multi-Class 
ETF Shares will be listed and traded on the Exchange subject to 
application of the continued listing criteria therein. Proposed Rule 
5703(d)(2)(A) provides that the Exchange will consider the suspension 
of trading in, and will initiate delisting proceedings under the Rule 
5800 Series of, a series of Multi-Class ETF Shares under any of the 
following circumstances: (i) if the Exchange becomes aware that the 
issuer of the Multi-Class ETF Shares is no longer in compliance with 
the requirements of Rule 6c-11 under the Investment Company Act or of 
the applicable exemptive relief applicable to Muti-Class ETF Shares; 
(ii) if any of the other listing requirements set forth

[[Page 22376]]

in this Rule are not continuously maintained; (iii) if, following the 
initial twelve month period after commencement of trading on the 
Exchange of a series of Multi-Class ETF Shares, there are fewer than 50 
beneficial holders of the series of Multi-Class ETF Shares for 30 or 
more consecutive trading days; or (iv) if such other event shall occur 
or condition exists which, in the opinion of the Exchange, makes 
further dealings on the Exchange inadvisable. Proposed Rule 
5703(d)(2)(B) provides that upon termination of an investment company, 
the Exchange requires that Multi-Class ETF Shares issued in connection 
with such entity be removed from Exchange listing.
    Proposed Rule 5703(e) provides that neither the Exchange, the 
Reporting Authority, nor any agent of the Exchange shall have any 
liability for damages, claims, losses or expenses caused by any errors, 
omissions, or delays in calculating or disseminating any current index 
or portfolio value; the current value of the portfolio of securities 
required to be deposited in connection with issuance of Multi-Class ETF 
Shares; the amount of any dividend equivalent payment or cash 
distribution to holders of Multi-Class ETF Shares; net asset value; or 
other information relating to the purchase, redemption, or trading of 
Multi-Class ETF Shares, resulting from any negligent act or omission by 
the Exchange, the Reporting Authority, or any agent of the Exchange, or 
any act, condition, or cause beyond the reasonable control of the 
Exchange, its agent, or the Reporting Authority, including, but not 
limited to, an act of God; fire; flood; extraordinary weather 
conditions; war; insurrection; riot; strike; accident; action of 
government; communications or power failure; equipment or software 
malfunction; or any error, omission, or delay in the reports of 
transactions in one or more underlying securities.
    The Exchange is also proposing to make corresponding amendments to 
include Multi-Class ETF Shares in other Exchange rules, which are 
intended to align the treatment of the proposed products with how other 
open-end management investment company shares (e.g., Exchange Traded 
Fund Shares, Index Fund Shares, and Managed Fund Shares) are treated 
under the Exchange's rules. First, the Exchange proposes to amend the 
definition of ``Derivative Securities'' in Rule 5615(a)(6)(B) to add 
Multi-Class ETF Shares so that Rule 5615(a)(6)(A) and its exemptions 
from certain corporate governance requirements are applicable to Multi-
Class ETF Shares.\15\
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    \15\ Rule 5615(a)(6)(A) provides that issuers whose only 
securities listed on Nasdaq are non-voting preferred securities, 
debt securities or Derivative Securities, are exempt from the 
requirements relating to Independent Directors (as set forth in Rule 
5605(b)), Compensation Committees (as set forth in Rule 5605(d)), 
Director Nominations (as set forth in Rule 5605(e)), Codes of 
Conduct (as set forth in Rule 5610), and Meetings of Shareholders 
(as set forth in Rule 5620(a)). In addition, these issuers are 
exempt from the requirements relating to Audit Committees (as set 
forth in Rule 5605(c)), except for the applicable requirements of 
SEC Rule 10A-3. Notwithstanding, if the issuer also lists its common 
stock or voting preferred stock, or their equivalent on Nasdaq it 
will be subject to all the requirements of the Nasdaq 5600 Rule 
Series.
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    Second, the Exchange proposes to amend the definition of 
``Derivative Securities Products in Rule 5705(b)(3)(A)(i)a. to add 
Multi-Class ETF Shares so the exclusions applicable to Derivative 
Securities Products in Nasdaq Rule 5705(b)(3)(A) will also apply to 
Multi-Class ETF Shares. The Exchange believes this is appropriate to 
ensure that Multi-Class ETF Shares are treated consistently with other 
open-end management investment company shares listed on the Exchange 
such as Exchange Traded Fund Shares, Index Fund Shares, and Managed 
Fund Shares.
    Third, the Exchange proposes to amend the definition of ``Exchange 
Traded Derivative Securities'' in Rule 5735(c)(6) to add Multi-Class 
ETF Shares so the exclusions applicable to Exchange Traded Derivative 
Securities in Rule 5735(b)(1)(A) will also apply to Multi-Class ETF 
Shares. The Exchange believes this is appropriate to ensure that Multi-
Class ETF Shares are treated consistently with other open-end 
management investment company shares listed on the Exchange such as 
Exchange Traded Fund Shares, Index Fund Shares, and Managed Fund 
Shares.
    Fourth, the Exchange proposes to amend Equity 4, Rule 4120 to 
include Multi-Class ETF Shares in the Exchange's trading halt 
provisions in Rule 4120(a)(9) and 4120(b)(4)(A).\16\ This will ensure 
the applicability of trading halts to the trading of Multi-Class ETF 
Shares listed on Nasdaq, and those traded on Nasdaq pursuant to 
unlisted trading privileges.
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    \16\ Rule 4120(b)(4)(A) sets out the definition of ``Derivative 
Securities Product,'' which is referenced in the Exchange's halt 
authority pursuant to Rules 4120(a)(10) and 4120(b).
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Discussion
    Proposed Rule 5703 is based in large part on Rules 5704, 5705(b), 
and 5735, related to the listing and trading of ETF Shares, Index Fund 
Shares, and Managed Fund Shares, respectively, each of which are issued 
under the Investment Company Act and qualify as ETF Shares under Rule 
6c-11. Rules 5705(b) and 5735 are very similar, their primary 
difference being that Index Fund Shares are designed to track an 
underlying index and Managed Fund Shares are based on an actively 
managed portfolio that is not designed to track an index. ETF Shares 
are identical to Multi-Class ETF Shares except that Multi-Class ETF 
Shares have received exemptive relief to operate an exchange-traded 
fund class in addition to classes of shares that are not exchange-
traded. As such, the Exchange believes that using Rules 5705(b) and 
5735 (collectively, the ``Current ETF Standards'') as well as Rule 5704 
as the basis for proposed Rule 5703 is appropriate because they are 
generally designed to address the issues associated with Multi-Class 
ETF Shares. The only substantial difference between Rule 5704 and 
proposed Rule 5703 from the Current ETF Standards that are not 
otherwise required under Rule 6c-11 is that proposed Rule 5703 and Rule 
5704 do not include the quantitative standards applicable to a fund or 
an index that are included in the Current ETF Standards. This 
difference is discussed below.
    The Exchange believes that the proposal is designed to prevent 
fraudulent and manipulative acts and practices because the Exchange 
will perform ongoing surveillance of Multi-Class ETF Shares listed on 
the Exchange in order to ensure compliance with Rule 6c-11, the 
Investment Company Act, and any applicable exemptive relief on an 
ongoing basis. While proposed Rule 5703 does not include the 
quantitative requirements applicable to an ETF or an ETF's holdings or 
underlying index that are included in Rules 5705(b) and 5735,\17\ the 
Exchange believes that the manipulation concerns that such standards 
are intended to address are otherwise mitigated by a combination of the 
Exchange's surveillance procedures, the Exchange's ability to halt 
trading under the proposed Rule 5703(d)(2)(B), and the Exchange's 
ability to suspend trading and commence delisting proceedings under 
proposed Rule 5703(d)(2)(A). The Exchange will halt

[[Page 22377]]

trading in the Shares under the conditions specified in Nasdaq Rules 
4120 and 4121, including without limitation the conditions specified in 
Nasdaq Rule 4120(a)(9) and (10) and under Nasdaq Rules 4120(a)(12). The 
Exchange also believes that such concerns are further mitigated by 
enhancements to the arbitrage mechanism that have come from Rule 6c-11, 
specifically the additional flexibility provided to issuers of Multi-
Class ETF Shares through the use of custom baskets for creations and 
redemptions and the additional information made available to the public 
through the additional daily website disclosure obligations applicable 
under Rule 6c-11.\18\ The Exchange believes that the combination of 
these factors will act to keep Multi-Class ETF Shares trading near the 
value of their underlying holdings and further mitigate concerns around 
manipulation of Multi-Class ETF Shares on the Exchange without the 
inclusion of quantitative standards.\19\ The Exchange will monitor for 
compliance with Rule 6c-11 and any applicable exemptive relief in order 
to ensure that the continued listing standards are being met.\20\ 
Specifically, the Exchange will review the website of each series of 
Multi-Class ETF Shares listed on the Exchange in order to ensure that 
the requirements of Rule 6c-11 are being met. The Exchange will also 
employ numerous intraday alerts that will notify Exchange personnel of 
trading activity throughout the day that is potentially indicative of 
certain disclosures not being made accurately or the presence of other 
unusual conditions or circumstances that could be detrimental to the 
maintenance of a fair and orderly market. As a backstop to the 
surveillances described above, the Exchange also notes that Rule 5703 
would require an issuer of Multi-Class ETF Shares to notify the 
Exchange of any failure to comply with Rule 6c-11 or the Investment 
Company Act.
---------------------------------------------------------------------------

    \17\ The Exchange notes that Rules 5705(b) and 5735 include 
certain quantitative standards related to the size, trading volume, 
concentration, and diversity of the holdings of a series of Index 
Fund Shares or Managed Fund Shares (the ``Holdings Standards'') as 
well as related to the minimum number of beneficial holders of a 
fund (the ``Distribution Standards''). The Exchange believes that to 
the extent that manipulation concerns are mitigated based on the 
factors described herein, such concerns are mitigated both as it 
relates to the Holdings Standards and the Distribution Standards.
    \18\ The Exchange notes that the Commission came to a similar 
conclusion in several places in the Rule 6c-11 Release. See Rule 6c-
11 Release at 15-18; 60-61; 69-70; 78-79; 82-84; and 95-96.
    \19\ The Exchange believes that this applies to all quantitative 
standards, whether applicable to the portfolio holdings of a series 
of Multi-Class ETF Shares or the distribution of the Multi-Class ETF 
Shares.
    \20\ As noted throughout, proposed Rule 5703, unlike Rule 
5705(b) and Rule 5735, does not include Holdings Standards and, as 
such, there will be no quantitative standards applicable by the 
Exchange to the portfolio holdings of a series of Multi-Class ETF 
Shares on an initial or continued listing basis.
---------------------------------------------------------------------------

    The Exchange may suspend trading in and commence delisting 
proceedings for a series of Multi-Class ETF Shares where such series is 
not in compliance with the applicable listing standards or where the 
Exchange believes that further dealings on the Exchange are 
inadvisable.\21\ The Exchange also notes that Rule 5701(d) requires any 
issuer to provide the Exchange with prompt notification after it 
becomes aware of any non-compliance with proposed Rule 5703, which 
would include any failure of the issuer to comply with Rule 6c-11, the 
Investment Company Act, or any exemptive relief applicable to Multi-
Class ETF Shares.\22\
---------------------------------------------------------------------------

    \21\ Specifically, proposed Rule 5703(d)(2) provides that each 
series of Multi-Class ETF Shares will be listed and traded on the 
Exchange subject to application of Proposed Rule 5703(d)(2)(A) and 
(B). Proposed Rule 5703(d)(2)(A) provides that the Exchange will 
consider the suspension of trading in, and will commence delisting 
proceedings under the Rule 5800 Series of, a series of Multi-Class 
ETF Shares under any of the following circumstances: (i) if the 
Exchange becomes aware that the issuer of the Multi-Class ETF Shares 
is no longer eligible to operate in reliance on Rule 6c-11 under the 
Investment Company Act of 1940 or any applicable exemptive relief 
applicable to Multi-Class ETF Shares; (ii) if any of the other 
listing requirements set forth in this Rule are not continuously 
maintained; (iii) if, following the initial twelve month period 
after commencement of trading on the Exchange of a series of Multi-
Class ETF Shares, there are fewer than 50 beneficial holders of the 
series of Multi-Class ETF Shares for 30 or more consecutive trading 
days; or (iv) if such other event shall occur or condition exists 
which, in the opinion of the Exchange, makes further dealings on the 
Exchange inadvisable. Proposed Rule 5703(d)(2)(B) provides that upon 
termination of an investment company, the Exchange requires that 
Multi-Class ETF Shares issued in connection with such entity be 
removed from Exchange listing.
    \22\ The Exchange notes that failure by an issuer to notify the 
Exchange of non-compliance pursuant to Rule 5701(d) would itself be 
considered non-compliance with the requirements of proposed Rule 
5703 and would subject the series of Multi-Class ETF Shares to 
potential trading halts and the delisting process under the Rule 
5800 Series.
---------------------------------------------------------------------------

    Further, the Exchange also represents that its surveillance 
procedures are adequate to properly monitor the trading of the Multi-
Class ETF Shares in all trading sessions and to deter and detect 
violations of Exchange rules and applicable federal securities laws. 
Specifically, the Exchange intends to utilize its existing surveillance 
procedures applicable to derivative products, which are currently 
applicable to ETF Shares, Index Fund Shares and Managed Fund Shares, 
among other product types, to monitor trading in Multi-Class ETF 
Shares. The Exchange or the Financial Industry Regulatory Authority, 
Inc. (``FINRA''), on behalf of the Exchange, will communicate as needed 
regarding trading in Multi-Class ETF Shares and certain of their 
applicable underlying components with other markets that are members of 
the Intermarket Surveillance Group (``ISG'') or with which the Exchange 
has in place a comprehensive surveillance sharing agreement. In 
addition, the Exchange may obtain information regarding trading in 
Multi-Class ETF Shares and certain of their applicable underlying 
components from markets and other entities that are members of ISG or 
with which the Exchange has in place a comprehensive surveillance 
sharing agreement. Finally, the issuer of a series of Multi-Class ETF 
Shares will be required to comply with Rule 10A-3 under the Act for the 
initial and continued listing of Multi-Class ETF Shares, as provided 
under Rule 5615(a)(6).\23\
---------------------------------------------------------------------------

    \23\ See supra note 15. The Exchange notes that these proposed 
changes in Rule 5615(a)(6)(B) would subject ETF Shares to the same 
corporate governance requirements as other open-end management 
investment companies listed on the Exchange.
---------------------------------------------------------------------------

    The Exchange notes that it may consider all relevant factors in 
exercising its discretion to halt or suspend trading in a series of 
Multi-Class ETF Shares. Trading may be halted if the circuit breaker 
parameters in Rule 4121 have been reached, because of other market 
conditions, or for reasons that, in the view of the Exchange, make 
trading in the Shares inadvisable. These may include: (1) the extent to 
which certain information about the Multi-Class ETF Shares that is 
required to be disclosed under Rule 6c-11 of the Investment Company Act 
is not being made available, including specifically where the Exchange 
becomes aware that the net asset value or the daily portfolio 
disclosure with respect to a series of Multi-Class ETF Shares is not 
disseminated to all market participants at the same time, it will halt 
trading in such series until such time as the net asset value or the 
daily portfolio disclosure is available to all market participants; 
\24\ (2) if an interruption to the dissemination to the value of the 
index or reference asset on which a series of Multi-Class ETF Shares is 
based persists past the trading day in which it occurred or is no 
longer calculated or available; (3) trading in the securities 
comprising the underlying index or portfolio has been halted in the 
primary market(s); or (4) whether other unusual conditions or 
circumstances detrimental to the maintenance of a fair and orderly 
market are present.
---------------------------------------------------------------------------

    \24\ The Exchange will obtain a representation from the issuer 
of Multi-Class ETF Shares that the net asset value per share will be 
calculated daily and the requirements under 6c-11 will be satisfied 
for the series will be calculated daily and made available to all 
market participants at the same time.
---------------------------------------------------------------------------

2. Statutory Basis
    The Exchange believes that its proposal is consistent with Section 
6(b)

[[Page 22378]]

of the Act,\25\ in general, and furthers the objectives of Section 
6(b)(5) of the Act,\26\ in particular, in that it is designed to 
promote just and equitable principles of trade, to remove impediments 
to and perfect the mechanism of a free and open market and a national 
market system, and, in general to protect investors and the public 
interest.
---------------------------------------------------------------------------

    \25\ 15 U.S.C. 78f(b).
    \26\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------

    The Exchange believes that proposed Rule 5703 is designed to 
prevent fraudulent and manipulative acts and practices in that the 
proposed rules relating to listing and trading Multi-Class ETF Shares 
on the Exchange provide specific initial and continued listing criteria 
required to be met by such securities. Proposed Rule 5703(d) sets forth 
initial and continued listing criteria applicable to Multi-Class ETF 
Shares, specifically providing that the Exchange may approve a series 
of Multi-Class ETF Shares for listing and/or trading (including 
pursuant to unlisted trading privileges) on the Exchange pursuant to 
Rule 19b-4(e) under the Act, provided such series of Multi-Class ETF 
Shares complies with the requirements of Rule 6c-11 under the 
Investment Company Act, and is eligible to operate in reliance on 
exemptive relief from certain requirements of the Investment Company 
Act and the rules and regulations thereunder that permits the fund to 
offer Multi-Class ETF Shares, and must satisfy the requirements of this 
Rule on an initial and continued listing basis.\27\ The Exchange will 
submit a Form 19b-4(e) for all series of Multi-Class ETF Shares upon 
being listed pursuant to Rule 5703 and such Form 19b-4(e) will 
specifically note that such series of Multi-Class ETF Shares are being 
listed on the Exchange pursuant to Rule 5703.
---------------------------------------------------------------------------

    \27\ The Exchange notes that eligibility to operate in reliance 
on Rule 6c-11 or any applicable exemptive relief thereunder does not 
necessarily mean that an investment company would be listed on the 
Exchange pursuant to proposed Rule 5703. To this point, an 
investment company that operates in reliance of exemptive relief 
providing for Multi-Class ETF Shares could also be listed as a 
series of Index Fund Shares or Managed Fund Shares pursuant to Rule 
5705(b) or 5735, respectively, and would be subject to all 
requirements under each of those rules. Further to this point, in 
the event that a series of Multi-Class ETF Shares listed on the 
Exchange preferred to be listed as a series of Index Fund Shares or 
Managed Fund Shares (as applicable), nothing would preclude such a 
series from changing to be listed as a series of Index Fund Shares 
or Managed Fund Shares (as applicable), as long as the series met 
each of the initial and continued listing obligations under the 
applicable rules.
---------------------------------------------------------------------------

    Proposed Rule 5704(d)(2) [sic] provides that each series of Multi-
Class ETF Shares will be listed and traded on the Exchange subject to 
application of proposed Rules 5704(d)(2)(A) [sic] and (B). Proposed 
Rule 5704(d)(2)(A) [sic] provides that the Exchange will consider the 
suspension of trading in, and will commence delisting proceedings under 
the Rule 5800 Series of, a series of Multi-Class ETF Shares under any 
of the following circumstances: (i) if the Exchange becomes aware that 
the issuer of the Multi-Class ETF Shares is no longer in compliance 
with the requirements of Rule 6c-11 under the Investment Company Act of 
1940 or the exemptive relief applicable to Multi-Class ETF Shares; (ii) 
if any of the other listing requirements set forth in this Rule 
14.11(n) are not continuously maintained; (iii) if, following the 
initial twelve month period after commencement of trading on the 
Exchange of a series of Multi-Class ETF Shares, there are fewer than 50 
beneficial holders of the series of Multi-Class ETF Shares for 30 or 
more consecutive trading days; or (d) if such other event shall occur 
or condition exists which, in the opinion of the Exchange, makes 
further dealings on the Exchange inadvisable. The Exchange notes that 
it may become aware that the issuer is no longer compliant with Rule 
6c-11 or any applicable exemptive relief thereunder, as described in 
proposed Rule 5703(d)(2)(A)(i), as a result of either the Exchange 
identifying non-compliance through its own monitoring process or 
through notification by the issuer.
    Proposed Rule 5703(d)(2)(B) provides that upon termination of an 
investment company, the Exchange requires that Multi-Class ETF Shares 
issued in connection with such entity be removed from Exchange listing. 
The Exchange also notes that it will obtain a representation from the 
issuer of each series of Multi-Class ETF Shares stating that the 
requirements of Rule 6c-11 will be continuously satisfied and that the 
issuer will notify the Exchange of any failure to do so.
    The Exchange further believes that proposed Rule 5703 is designed 
to prevent fraudulent and manipulative acts and practices because of 
the robust surveillances in place on the Exchange as required under 
proposed Rule 5703(b)(2) along with the similarities of proposed Rule 
5703 to the rules related to other securities that are already listed 
and traded on the Exchange and which would qualify as Multi-Class ETF 
Shares. Proposed Rule 5703 is based in large part on Rules 5705(b) and 
5735 related to the listing and trading of Index Fund Shares and 
Managed Fund Shares on the Exchange, respectively, both of which are 
issued under the 1940 Act and would qualify as Multi-Class ETF Shares. 
Rules 5705(b) and 5735 are very similar, their primary difference being 
that Index Fund Shares are designed to track an underlying index and 
Managed Fund Shares are based on an actively managed portfolio that is 
not designed to track an index. ETF Shares are identical to Multi-Class 
ETF Shares except that Multi-Class ETF Shares have received exemptive 
relief to operate an exchange-traded fund class in addition to classes 
of shares that are not exchange-traded. As such, the Exchange believes 
that using the Current ETF Standards and Rule 5704 as the basis for 
proposed Rule 5703 is appropriate because they are generally designed 
to address the issues associated with Multi-Class ETF Shares. The only 
substantial difference between proposed Rule 5703 and the Current ETF 
Standards that are not otherwise required under Rule 6c-11 is that 
proposed Rule 5703 does not include the quantitative standards 
applicable to a fund or an index that are included in the Current ETF 
Standards.
    The Exchange believes that the proposal is consistent with Section 
6(b)(1) of the Act \28\ in that, in addition to being designed to 
prevent fraudulent and manipulative acts and practices, the Exchange 
has the capacity to enforce proposed Rule 5703 by performing ongoing 
surveillance of Multi-Class ETF Shares listed on the Exchange in order 
to ensure compliance with Rule 6c-11 and the 1940 Act on an ongoing 
basis. While proposed Rule 5703 does not include the quantitative 
requirements applicable to a fund and a fund's holdings or underlying 
index that are included in Rules 5705(b) and 5735,\29\ the Exchange 
believes that the manipulation concerns that such standards are 
intended to address are otherwise mitigated by a combination of the 
Exchange's surveillance procedures, the Exchange's ability to halt 
trading under the proposed Rule 5703(d)(2)(B), and the Exchange's 
ability to suspend trading and commence delisting proceedings under 
proposed Rule 5703(d)(2)(A). The Exchange also believes that such 
concerns are further mitigated by enhancements to the arbitrage 
mechanism that have come from compliance with Rule 6c-11, specifically 
the additional flexibility provided to issuers of Multi-Class ETF

[[Page 22379]]

Shares through the use of custom baskets for creations and redemptions 
and the additional information made available to the public through the 
additional daily website disclosure obligations applicable under Rule 
6c-11.\30\ The Exchange believes that the combination of these factors 
will act to keep Multi-Class ETF Shares trading near the value of their 
underlying holdings and further mitigate concerns around manipulation 
of Multi-Class ETF Shares on the Exchange without the inclusion of 
quantitative standards.\31\ The Exchange will monitor for compliance 
with Rule 6c-11 and any applicable exemptive relief in order to ensure 
that the continued listing standards are being met. Specifically, the 
Exchange plans to review the website of series of Multi-Class ETF 
Shares in order to ensure that the requirements of Rule 6c-11 are being 
met. The Exchange will also employ numerous intraday alerts that will 
notify Exchange personnel of trading activity throughout the day that 
is potentially indicative of certain disclosures not being made 
accurately or the presence of other unusual conditions or circumstances 
that could be detrimental to the maintenance of a fair and orderly 
market. As a backstop to the surveillances described above, the 
Exchange also notes that Rule 5701(d) would require an issuer of Multi-
Class ETF Shares to notify the Exchange of any failure to comply with 
Rule 6c-11 or the Investment Company Act.
---------------------------------------------------------------------------

    \28\ 15 U.S.C. 78f(b)(1).
    \29\ The Exchange notes that Rules 5705(b) and 5735 include 
certain Holdings Standards and Distribution Standards. The Exchange 
believes that to the extent that manipulation concerns are mitigated 
based on the factors described herein, such concerns are mitigated 
both as it relates to the Holdings Standards and the Distribution 
Standards.
    \30\ The Exchange notes that the Commission came to a similar 
conclusion in several places in the Rule 6c-11 Release. See Rule 6c-
11 Release at 15-18; 60-61; 69-70; 78-79; 82-84; and 95-96.
    \31\ The Exchange believes that this applies to all quantitative 
standards, whether applicable to the portfolio holdings of a series 
of Multi-Class ETF Shares or the distribution of the Multi-Class ETF 
Shares.
---------------------------------------------------------------------------

    To the extent that any of the requirements under Rule 6c-11 or the 
1940 Act are not being met, the Exchange may halt trading in a series 
of Multi-Class ETF Shares as provided in proposed Rule 5703(d)(2)(B). 
Further, the Exchange may also suspend trading in and commence 
delisting proceedings for a series of Multi-Class ETF Shares where such 
series is not in compliance with the applicable listing standards or 
where the Exchange believes that further dealings on the Exchange are 
inadvisable. As discussed above, the Exchange also notes that Rule 
5701(d) requires any issuer to provide the Exchange with prompt 
notification after it becomes aware of any non-compliance with proposed 
Rule 5703, which would include any failure of the issuer to comply with 
Rule 6c-11 or the 1940 Act.
    Further, the Exchange also represents that its surveillance 
procedures are adequate to properly monitor the trading of the Multi-
Class ETF Shares in all trading sessions and to deter and detect 
violations of Exchange rules. Specifically, the Exchange intends to 
utilize its existing surveillance procedures applicable to derivative 
products, which are currently applicable to Index Fund Shares, Managed 
Fund Shares and ETF Shares, among other product types, to monitor 
trading in Multi-Class ETF Shares. The Exchange or FINRA, on behalf of 
the Exchange, will communicate as needed regarding trading in Multi-
Class ETF Shares and certain of their applicable underlying components 
with other markets that are members of the ISG or with which the 
Exchange has in place a comprehensive surveillance sharing agreement. 
In addition, the Exchange may obtain information regarding trading in 
Multi-Class ETF Shares and certain of their applicable underlying 
components from markets and other entities that are members of ISG or 
with which the Exchange has in place a comprehensive surveillance 
sharing agreement.
    Additionally, FINRA, on behalf of the Exchange, is able to access, 
as needed, trade information for certain fixed income securities that 
may be held by a series of Multi-Class ETF Shares reported to FINRA's 
TRACE. FINRA also can access data obtained from the MSRB's EMMA system 
relating to municipal bond trading activity for surveillance purposes 
in connection with trading in a series of Multi-Class ETF Shares, to 
the extent that a series of Multi-Class ETF Shares holds municipal 
securities. Finally, as noted above, the issuer of a series of Multi-
Class ETF Shares will be required to comply with Rule 10A-3 under the 
Act for the initial and continued listing of Multi-Class ETF Shares, as 
provided under Rule 5615(a)(6).\32\
---------------------------------------------------------------------------

    \32\ See supra notes 15 and 23.
---------------------------------------------------------------------------

    The Exchange believes that permitting Multi-Class ETF Shares to 
list on the Exchange is consistent with the applicable exemptive relief 
and will help perfect the mechanism of a free and open market and, in 
general, will protect investors and the public interest in that it will 
permit the listing and trading of Multi-Class ETF Shares, consistent 
with the applicable exemptive relief, and in a manner that will benefit 
investors. Specifically, the Exchange believes that the relief proposed 
in the Applications and the expected benefits of the Multi-Class ETF 
Shares described above would be to the benefit of investors. 
Eliminating any unnecessary delay for additional Multi-Class ETF Shares 
listing on the Exchange under proposed Rule 5703 will simply help 
accrue those benefits to investors more expeditiously. Further, the 
Exchange is only proposing to amend its rules to allow such a series of 
Multi-Class ETF Shares to list on the Exchange pursuant to Rule 5703, a 
change to its rules that will only be meaningful if and when the 
Commission grants such relief to an Applicant. As noted above, the 
Exchange submits this proposal only to prevent any unnecessary delay in 
listing additional Multi-Class ETF Shares generically under Rule 5703 
when and if such requests are granted by the Commission.
    The Exchange also believes that proposed Rule 5703 to explicitly 
provide the initial and continued listing standards applicable to 
Multi-Class ETF Shares, including the suspension of trading or removal 
standards, are designed to promote transparency and clarity in the 
Exchange's Rules. The Exchange believes that with these changes, Rule 
5703 would clearly allow for the listing and trading of Multi-Class ETF 
Shares upon the Commission's order of exemptive relief.
    The Exchange also believes that the corresponding changes to add 
Multi-Class ETF Shares in the Exchange's corporate governance 
requirements under Rule 5615(a)(6)(B), the Index Fund Shares provisions 
in Rule 5705(b), the Managed Fund Shares provisions in Rule 5735, and 
the trading halt provisions in Equity 4, Rule 4120, each as discussed 
in detail above, will add clarity to the Exchange's Rulebook. ETF 
Shares, Managed Fund Shares, and Index Fund Shares are similarly 
included in these provisions. Therefore, the Exchange believes these 
are non-substantive changes meant only to subject Multi-Class ETF 
Shares to the same exemptions and provisions currently applicable to 
Index Fund Shares, Managed Fund Shares, and ETF Shares so that the 
treatment of these open-end management investment companies is 
consistent under the Exchange's rules.
    For the above reasons, the Exchange believes that the proposed rule 
change is consistent with the requirements of Section 6(b)(5) of the 
Act.

B. Self-Regulatory Organization's Statement on Burden on Competition

    The Exchange does not believe that the proposed rule change will 
impose any burden on competition not

[[Page 22380]]

necessary or appropriate in furtherance of the purposes of the Act. The 
Exchange believes the proposal, by permitting the listing and trading 
of Multi-Class ETF Shares under exemptive relief from the Investment 
Company Act and the rules and regulations thereunder, would introduce 
additional competition among various ETF products to the benefit of 
investors.

C. Self-Regulatory Organization's Statement on Comments on the Proposed 
Rule Change Received From Members, Participants, or Others

    No written comments were either solicited or received.

III. Date of Effectiveness of the Proposed Rule Change and Timing for 
Commission Action

    Within 45 days of the date of publication of this notice in the 
Federal Register or within such longer period up to 90 days (i) as the 
Commission may designate if it finds such longer period to be 
appropriate and publishes its reasons for so finding or (ii) as to 
which the Exchange consents, the Commission shall: (a) by order approve 
or disapprove such proposed rule change, or (b) institute proceedings 
to determine whether the proposed rule change should be disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and 
arguments concerning the foregoing, including whether the proposed rule 
change is consistent with the Act. Comments may be submitted by any of 
the following methods:

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>); or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#d1a3a4bdb4fcb2bebcbcb4bfa5a291a2b4b2ffb6bea7"><span class="__cf_email__" data-cfemail="4a383f262f67292527272f243e390a392f29642d253c">[email&#160;protected]</span></a>. Please include 
file number SR-NASDAQ-2025-037 on the subject line.

Paper Comments

    <bullet> Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to file number SR-NASDAQ-2025-037. This 
file number should be included on the subject line if email is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (<a href="https://www.sec.gov/rules/sro.shtml">https://www.sec.gov/rules/sro.shtml</a>). Copies of the submission, all subsequent amendments, all 
written statements with respect to the proposed rule change that are 
filed with the Commission, and all written communications relating to 
the proposed rule change between the Commission and any person, other 
than those that may be withheld from the public in accordance with the 
provisions of 5 U.S.C. 552, will be available for website viewing and 
printing in the Commission's Public Reference Room, 100 F Street NE, 
Washington, DC 20549, on official business days between the hours of 10 
a.m. and 3 p.m. Copies of the filing also will be available for 
inspection and copying at the principal office of the Exchange. Do not 
include personal identifiable information in submissions; you should 
submit only information that you wish to make available publicly. We 
may redact in part or withhold entirely from publication submitted 
material that is obscene or subject to copyright protection. All 
submissions should refer to file number SR-NASDAQ-2025-037 and should 
be submitted on or before June 17, 2025.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\33\
---------------------------------------------------------------------------

    \33\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-09387 Filed 5-23-25; 8:45 am]
BILLING CODE 8011-01-P


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Indexed from Federal Register on May 27, 2025.

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.