In November, the SEC issued a concept release on actively managed ETFs and asked for comments from the industry on the would-be products no later than January 14. In its letter dated January 14, the Investment Company Institute addressed several concerns, specifically its main concern over portfolio holdings disclosure.

The holdings of traditional index-based ETFs are transparent, which allows the market maker to keep the price very close to the fund's NAV and avoid substantial premiums or discounts on the fund. That would not be the case with an actively managed ETF, however, that does not disclose its holdings.

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