PURPOSE

• To enable investors to identify and access key information clearly and concisely.
• To provide a layered disclosure framework that highlights information investors most frequently seek while still providing the extended disclosure required by the regulation.

ENTITIES AFFECTED

• Open-end funds and ETFs filing on Form N-1A
• Excludes CEFs and BDCs filing on Form N-2
• Fee and expense advertising changes applicable to all registered funds

KEY COMPONENTS

1. Updated annual and semi-annual report: Tailored Shareholder Report (TSR)
2. TSR Content
3. Updated Form N-CSRStructured Data (iXBRL Tagging) for TSRs
4. Updated Form N-CSR
5. Changes to Rule 30e-3 and Accessibility

ADDITIONAL COMPONENTS

• Defining a broad-based securities market index
• Fee and expense information in advertising
• Form N-1A amendments

KEY COMPONENTS

1. Updated Report, Tailored Shareholder Report (TSR)
   FORMAT
   • TSR will be the new annual and semi-annual report
   • 2-4 page document highlighting key fund information
   • No limit to the number of pages, however, intended to be concise
   • One fund and one share class included per TSR
   • Multiple funds or multiple share classes cannot be combined
   • Content must appear in the order instructed by Item 27A of Form N-1A and only include information permitted by the new Item 27A
   • Not required to be audited
   • Must be filed on the SEC EDGAR system
2. TSR Content
   CONTENT
   1. General information:
      • Fund name, Class name, Ticker
      • Report label
      • Legend disclosing where additional information can be accessed
      • Statement regarding material changes
   2. Expense table identifying costs associated with a $10,000 investment (presented as both a percentage and dollar amount)
   3. Management’s “summary” of key factors impacting fund performance (graphic representation and bullets encouraged)
   4. Line graph or average annual returns table specific to share class comparing to appropriate broad-based securities market index (included in both TSR and AR)
   5. Graphical representation of holdings (table or graphic)
   6. Key fund statistics:
      • Net assets
      • Total number of holdings
      • Portfolio turnover rate
      • Total advisory fees paid
   7. Changes or disagreements with accountants
   8. Material changes (identified in prominent statement on cover page):
      • Fund name
      • Investment objectives
      • Principal investment strategies or risks
      • Annual operating expenses, shareholder fees, or maximum account fees
      • Investment adviser(s) or subadviser(s)
      • Optional additional material changes
   9. Availability of additional information
3. Structured Data for TSR
   • TSR items will require inline XBRL tagging for submission on the SEC EDGAR system.
   • N-CSR items will not require inline XBRL tagging for submission on the SEC EDGAR system.
4. Updated Form N-CSR
   FORMAT
   • Filed for multiple funds and share classes
   • Integrates TSRs as Item 1 on Form N-CSR, including inline XBRL tagging
   • Financial statements are included under Item 7
   • Financial statements for the annual report period must be audited, consistent with current requirements
   • Must be posted to fund website by day 60
   • Must be filed on EDGAR by day 70
   • Must be available to be printed and mailed upon request

   Content Moved from Legacy Annual and Semi-Annual Report to Form N-CSR

   • Financial statements (Item 7.a)
     • Schedule of Investments, Statement of Assets and Liabilities, Statement of Operations, Changes in Net Assets
   • Financial highlights (Item 7.c)
   • Results of any shareholder vote during period (Item 9)
   • Remuneration paid to directors, officers, and others (Item 10)
   • Approval of investment advisory agreement (Item 11)

   Additional Notes:

   • Manager’s discussion and analysis (condensed and only exists in TSR)
   • Expense table (condensed and only exists in TSR)
   • Management table (removed from shareholder report and Form N-CSR)
   • Liquidity risk management disclosure (removed from shareholder report and Form N-CSR)
5. Rule 30e-3 and Accessibility
   30e-3 CHANGES
   • Open-end funds and ETFs will no longer be allowed to rely on rule 30e-3 to provide notice of the availability of the shareholder report.
   • Closed-end funds will still be allowed to rely on rule 30e-3.

   PRINTING AND MAILING

   • Shareholders will only receive a TSR for each series and class in which they invest.
   • While TSRs must be created for a single share class per fund, they can be delivered together.
   • Same as existing requirements, TSRs must be delivered by day 60 and filed by day 70.
   • Funds must still fulfill any paper requests for the full Form N-CSR.

   ONLINE AVAILABILITY

   • TSRs and Form N-CSR must be posted on the fund website 60 days after period end.
   • TSRs must link to the applicable semi- or annual Form N-CSR via “one-click.”
   • TSRs are encouraged to be visually engaging and easy to navigate on the fund website.
   • First and third quarter portfolio holdings are now required to be posted on a fund website 60 days after period end (previously only a requirement if utilizing rule 30e-3).
   • Electronic material is requirement of all to be ADA accessible.

ADDITIONAL COMPONENTS

• Defining a broad-based securities market index
  • A primary index must reflect the overall applicable market.
  • A more narrowly focused index may be used, but only as a secondary index.
• Fee and expense information in advertising
  • Applicable to all investment companies and BDCs if including fee related fee or expense information
  • Advertisements must include the maximum amount of any sales load or nonrecurring fee and total annual expenses without a fee waiver or expense reimbursement.
  • Fee information must be current as of last prospectus or annual report.
• Form N-1A Amendments
  • Funds are permitted to disclose statice dates such as birth year or year service began instead of age or years of services of fund officers, directors and portfolio managers.
  • Option (not requirement) to include Financial Highlights as incorporated by reference to Form N-CSR pending a disclosure statement on the cover and providing Form N-CSR to any new investors.

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