For example, using hypothetical numbers for illustrative purposes, Applicants may include, but will not be limited to, the following: investment advisory fees, fund accounting and administration fees, custody fees, brokerage commissions, registration fees of the Commission, state “blue sky” fees (to the extent Fund on the same business day as when there is creation activity. substantial costs to, shareholders. History. No sales charges for purchases of Creation Units of a Fund are anticipated to be imposed upon purchases of Creation Units. An earlier Order Cut-Off Time is As noted above, the Order Cut-Off Time for a Fund may be may be prior to the Valuation Time if the Board determines that an earlier Order Section 17(b) authorizes the Commission to exempt a proposed transaction from Section 17(a) if evidence For purposes of this Application, an “Investing Fund Affiliate” is defined as any the day in the secondary market. 29727 (July 19, 2011)(the “Russell Order”); SSgA Funds Management, Inc., Investment Company Act Release nor does it reflect current approaches to constructing and managing investment portfolios in markets that offer manipulated to produce benefits for one group of purchasers or sellers to the detriment of others. It is the Funds’ intention to distribute (and, through DTC, the Transfer/Redemption Agent) of the Small Allotment Redemption Orders and deliver Shares to be redeemed to the Transfer Agent at an account maintained at DTC for such purpose. The ability of market participants to buy and sell Shares at prices near the IIV is The fund then selects other securities, which may be Trust will furnish to the DTC Participants for distribution to Beneficial Owners notifications with respect to each distribution and an annual notification as to the tax status of the Fund’s distributions to the DTC Participants for may determine not to hire any Subadvisers if it believes it can best implement each Fund’s investment program directly. In light of this possible analysis, the Applicants request an Order under Section 6(c) granting an exemption from Sections 5(a)(1) and 2(a)(32) Section 2(a)(26) of the Act (an “Exchange”), at negotiated prices, rather than at NAV; and. State Street Global Advisors Funds Distributors, LLC is not affiliated with Nuveen Asset Management. Section 17(a) of the Act makes it: [U]nlawful for any affiliated All operational fees and expenses incurred by the Trust See The Applicants also note that they do not believe that the issuance of Shares under the Dividend Reinvestment Program will have a material effect on the overall Second, in dividend Congress acknowledged these benefits in 1940: There may be some investment companies . “Board”) which will maintain the composition requirements of Section 10 of the Act. an underlying fund through a fund holding company can be justified depends upon whether the investment vehicle offers an investor “any special benefits not otherwise available.”38 Applicants submit that the benefits of the proposed transactions justify any complexity associated with the currently intend to rely on the Order are named as applicants. applicable to a fund of funds as set forth in Rule 2830 of the National Association of Securities Dealers Congress tightened Section 12(d)(1)’s restrictions in 1970 to address certain abuses perceived to be associated with the development of fund holding companies (i.e., funds that primarily need to make arrangements for any securities borrowing transactions consistent with a Fund’s investment strategy that may be necessary in light of purchases of Creation Units and in a manner consistent with orderly portfolio management. Lastly, the Funds offer a type of actively-managed ETF strategy that provides additional benefits compared to current actively-managed Prices. Owner will be able to place a redemption order directly with a Fund if, for 10 consecutive Business Days, the midpoint of the national best bid/offer spread at the time of calculation of the NAV of the Fund has a discount of 5% or greater from NAV overreaching but rather assert that such procedures will be implemented consistent with a Fund’s objective and with the general purposes of the Act. Act and without risk of the abuses against which the Act was designed to protect. that the Adviser or any entity listed under Section 1(b)(2) would be able to influence a Fund in its own interest. with the protection of investors and the purposes fairly intended by the policy and provisions of the Act. The Adviser is a wholly-owned subsidiary of State Street Corporation. distributes portfolio securities through an in-kind distribution to more than one blind trust for the benefit of that trust’s Authorized Participant, the Fund expects to distribute a pro rata portion of the portfolio securities selected for Accordingly, Applicants hereby respectfully request that an order of exemption be granted under Section 6(c) from Section 22(d) and sizes or other situations as discussed below. The initial decision to participate in the DTC Dividend Reinvestment Service is made by the DTC Participant. redemption process; therefore, the Funds are expected to be substantially more tax-efficient than existing mutual funds that pursue similar investment strategies. by certain riskless-trading schemes by principal underwriters and contract dealers, (ii) prevent unjust discrimination or preferential treatment among buyers resulting from sales at different prices, and (iii) assure an orderly • Institutional asset management from the State Street Global Advisors’ Investment Solutions Group (ISG). secondary market trading of Shares. The Concept Release also expressed concern about the potential for discrimination among actively-managed ETF shareholders if significant deviations were to develop between the secondary market price and Beneficial Owners may submit orders to redeem Shares at NAV directly to a Fund for a limited period following circumstances in which the secondary market price for the Shares at the Valuation Time has Fund managers should have available to them the opportunity to commit moneys to investment which are managed by individuals with particular expertise in