SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

Correspondence 0000051931-24-000389 from Capital Group Conservative Equity ETF (CIK 0002008359)

Capital Group Conservative Equity ETF (CIK 0002008359)
Date: April 9, 2024 · CIK: 0002008359 · Accession: 0000051931-24-000389

AI Filing Summary & Sentiment

File numbers found in text: 333-276927, 333-276928, 333-276930, 333-276931, 811-23933, 811-23934, 811-23935, 811-23936

Date
April 9, 2024
Author
Not clearly detected
Form
CORRESP
Company
Capital Group Conservative Equity ETF (CIK 0002008359)

Letter

Division of Investment Management File Nos. 333-276927, 811-23934 Capital Group Conservative Equity ETF (“Conservative Equity”) Initial Registration Statement on Form N-1A File Nos. 333-276928, 811-23933

Dear Mr. Worthington:

In response to your comment letter, dated March 6, 2024, to the initial registration statements on Form N-1A (the “Registration Statements”) of New Geography Equity, International Core Equity, Global Equity and Conservative Equity (each, a “Registrant” and together, the “Registrants”), we hereby file Pre-Effective Amendment No. 1 to the Registration Statements under the Investment Company Act of 1940 (the “1940 Act”) (such amendment, the “Amendment”) pursuant to Rule 472 of the 1933 Act. We appreciate your prompt response to the filing.

Our responses to your comments are set forth below. The Amendment reflects additional information that was not contained in the initial Registration Statements.

General

1. We note that the registration statements are missing information and exhibits and contain bracketed disclosures. We may have comments on such portions when you complete them in a pre-effective amendment, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: We have updated the Registration Statements in a pre-effective amendment to address this comment. We will also provide any outstanding information or exhibits in a subsequent pre-effective amendment. We acknowledge that you may have additional comments.

2. Please advise us if you have submitted or expect to submit any exemptive applications or no-action requests in connection with the registration statements.

Response: The Registrants do not presently intend to rely on any exemptive relief. However, as disclosed in each Registration Statement: “While it has no present intention of doing so, the fund’s board could determine that it is in the best interests of the fund not to publicly disclose the fund’s complete portfolio holdings on a daily basis. In such event, and upon prior written notice to shareholders, the fund will be required to rely on exemptive relief granted by the SEC, or rule or regulation in force at such time, to disclose its full portfolio holdings on a quarterly basis, similar to mutual funds.” We confirm supplementally that an application was filed on April 30, 2021, and amended on August 25, 2021, for an order under Section 6(c) of the 1940 Act for an exemption from Sections 2(a)(32), 5(a)(1), 22(d) and 22(e) of the 1940 Act and Rule 22c-1 under the 1940 Act, and under Sections 6(c) and 17(b) of the 1940 Act for an exemption from Sections 17(a)(1) and 17(a)(2) of the 1940 Act, and under Section 12(d)(1)(J) of the 1940 Act for an exemption from Sections 12(d)(1)(A) and 12(d)(1)(B) of the 1940 Act. If and when granted, such relief would allow the Registrants flexibility to convert to a less transparent fund structure (in each case subject to board approval and prior written notice to shareholders), which would allow the Registrants to disclose their portfolio holdings on a quarterly rather than daily basis.

3. Where a comment is made with regard to disclosure in one location of a registration statement, it is applicable to all similar disclosure appearing elsewhere in all four registration statements.

Response: We acknowledge this comment and have addressed the comments accordingly.

Capital Group New Geography Equity ETF

Principal Investment Strategies, Page 2

4. The first sentence of the first paragraph discloses that “The fund invests primarily in common stocks of companies with significant exposure to countries with developing economies and/or markets [emphasis added]. The securities markets of these countries may be referred to as emerging markets. [emphasis added].”

a. Please clarify the disclosure to explain what countries or markets would be considered “developing.”

Response: In keeping with the Staff’s guidance on layered disclosure, the characteristics of developing countries are described in the fund’s prospectus in the risk factor titled “Investing in developing countries”, and additional detail is provided in the fund’s statement of additional information in the risk factor titled “Investing in developing countries”. In addition, the fund’s prospectus includes disclosure of factors considered by the fund’s investment adviser in determining whether a developing country is a “qualified developing country” for the fund. For additional clarity, we will also supplement the disclosure of the fund’s principal investment strategies in both the fund’s summary and statutory prospectuses to include the following disclosure after the description of such factors:

In some cases, a country with a less developed economy may nevertheless be deemed a developed country by the fund’s investment adviser when assessed using the qualifying factors described above. In these cases, a country that more closely resembles developed countries relative to other developing countries when assessed along such criteria may be deemed a developed country. South Korea and Taiwan, for example, are deemed developed countries (and not qualified developing countries) for purposes of the fund's investment strategy.

b. Please supplementally explain to the Staff the inclusion of both “markets” and “economies.” Please clarify the distinction in the disclosure.

Response: To clarify the disclosure, we will update the disclosure to replace references to “countries with developing economies and/or markets” with references to “developing countries”.

c. Please clarify if there is a difference between “developing economies and/or markets” and “qualified countries.”

Response: “Qualified countries” are developing countries that the fund’s investment adviser has determined are “qualified” as described in additional detail in the “Investment objective, strategies and risks” section of the fund’s statutory prospectus. As a result, certain developing countries may not be considered a “qualified country” for the fund. To provide additional clarity regarding the difference between qualified developing countries and nonqualified developing countries, we will supplement the disclosure as follows:

In determining whether a country is a qualified developing country, the fund’s investment adviser considers such factors as the country’s per capita gross domestic product, the percentage of the country’s economy that is industrialized, market capital as a percentage of gross domestic product, the overall regulatory environment, the presence of government regulation limiting or banning foreign ownership, and restrictions on repatriation of initial capital, dividends, interest and/or capital gains. When assessed along these criteria, a qualified developing country will generally resemble developed countries more closely relative to nonqualified developing countries.

d. While the Staff notes the disclosure within the first paragraph that “securities markets in [developing] countries may be referred to as emerging markets,” please supplementally explain the use of the term, “developing economies and/or markets” as opposed to “emerging markets.”

Response: To clarify the use of the term, we will update the disclosure to replace references to “countries with developing economies and/or markets” with references to “developing countries”. For additional clarity, we will also supplement the quoted disclosure to say “[t]he securities markets of these countries may be referred to as emerging markets or frontier markets,” and we will also supplement the disclosure of the fund’s principal investment strategies in both the fund’s summary and statutory prospectuses to include the additional disclosure described in our response to Comment 4(a) above.

e. Please clarify the extent to which the New Geography Equity intends to invest in US issuers that would qualify as eligible for inclusion in the New Geography Equity’s portfolio.

Response: We confirm supplementally that, while fund may invest in US issuers, it is not a principal investment strategy of the fund to invest in securities of US issuers. Accordingly, we respectfully decline to supplement the disclosure as proposed.

5. Within the third sentence of the first paragraph, New Geography Equity discloses that it will consider any company for investment regardless of where it domiciled if “a significant portion of the company’s assets or revenues (generally [emphasis added] 20% or more) is attributable to developing countries.” Please explain the use of the qualifier, “generally”.

Response: We confirm supplementally that 20% is the threshold generally used for determining whether a significant portion of a company’s assets or revenues is attributable to developing countries. However, in certain instances, the fund may invest in a company with a different percentage of assets or revenues attributable to developing countries when the fund’s investment adviser determines such percentage should be appropriately considered a significant portion of the company’s assets or revenues based on the specific facts and circumstances. As a result, we have included the qualifier “generally” in this disclosure.

6. The first sentence of the second paragraph discloses that New Geography Equity invests at least 30% of its assets in equity securities of issuers domiciled in qualified countries that have developing economies. Furthermore, the third paragraph, states that, “In determining whether a country is qualified, the fund’s investment adviser considers such factors as [emphasis added] the country’s per capita gross domestic product, the percentage of the country’s economy that is industrialized, market capital as a percentage of gross domestic product, the overall regulatory environment, the presence of government regulation limiting or banning foreign ownership, and restrictions on repatriation of initial capital, dividends, interest and/or capital gains. The fund’s investment adviser maintains a list of qualified countries and securities in which the fund may invest.”

a. Please disclose all factors the adviser considers in determining what constitutes a qualifying country.

Response: We confirm supplementally that the factors disclosed in the prospectus are the primary factors considered in determining whether a country is a qualifying country. However, we do not believe it is reasonable or necessarily helpful to investors to list all possible factors that might be relevant to the determination of whether a particular country is a qualifying country. Accordingly, we respectfully decline to supplement the disclosure as proposed.

b. Please disclose which countries the adviser considers “qualifying.”

Response: The list of qualified countries is included in the section captioned “Investment objectives, strategies and risks” in the fund’s statutory prospectus. Such list is only included in the statutory prospectus in accordance with the Staff’s guidance that disclosure in response to Item 4 of Form N-1A should summarize the more fulsome disclosure in Item 9 of Form N-1A. Accordingly, we respectfully decline to supplement the disclosure as proposed.

c. The Staff notes that New Geography Equity lists some of the countries it will invest in within the Statutory Prospectus. Please include a list of all countries New Geography Equity will invest in within the Summary Strategy section.

Response: As described above, the list included in the statutory prospectus is a list of “qualified” countries. However, the fund may invest in securities of issuers domiciled in any country, including developed countries, as described in the fund’s prospectus and statement of additional information. As a result, we do not believe it is reasonable or necessarily helpful to investors to list all countries in which the fund may invest. We further believe that the list of qualified countries is appropriately disclosed in the statutory prospectus rather than the summary, in keeping with longstanding staff guidance on layered disclosure. Accordingly, we respectfully decline to supplement the disclosure as proposed. However, to provide additional clarity, we will revise the description of the list of qualified countries in the fund’s statutory prospectus as follows:

As of [May 1], 2024, the Qqualified developing countries in which the fund may invest currently include, but are not limited to, are Argentina, Bahrain, Bangladesh, Belarus, Belize, Bolivia, Botswana, Brazil, Bulgaria, Chile, China, Colombia, Costa Rica, Croatia, Czech Republic, Dominican Republic, Ecuador, Egypt, El Salvador, Estonia, Gabon, Ghana, Greece, Hungary, India, Indonesia, Iraq, Jamaica, Jordan, Kazakhstan, Kenya, Kuwait, Latvia, Lebanon, Lithuania, Macau, Malaysia, Mauritius, Mexico, Morocco, Namibia, Oman, Pakistan, Panama, Paraguay, Peru, Philippines, Poland, Qatar, Romania, Russian Federation, Saudi Arabia, Serbia, Slovakia, South Africa, Sri Lanka, Thailand, Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, Uruguay, Venezuela, Vietnam and Zambia.

7. The second sentence of the second paragraph discloses that “The fund may also, to a limited extent, invest in securities of issuers domiciled in nonqualified developing countries.” Please explain supplementally the use of the qualifier “to a limited extent.” Please disclose the specific risks associated with investing in issuers domiciled in such “non-qualifying developing countries” if such investments will be part of the fund’s principal investment strategies.

Response: The disclosure that the fund will invest in nonqualified developing countries “to a limited extent” should be read consistent with the plain meaning of such term. The fund does not expect to invest materially in such countries, and it will not be a part of the fund’s principal investment strategies to invest in such countries.

8. Please consider redrafting the order of disclosure in the Summary Strategy Section to disclose 1) the 80% test in equities, 2) New Geography Equity’s principal exposure to issuers with significant exposure to developing countries, 3) the 30% investment in issuers domiciled in qualifying countries, 4) and the limited exposure to issuers in non-qualifying countries.

Response: We will redraft the order of disclosure as requested.

9. The fourth paragraph discloses that, “The investment adviser uses a system of multiple portfolio managers in managing assets. Under this approach, a portfolio is divided into segments managed by individual managers. For more information regarding the investment process of the fund, see the ‘Management and organization’ section of this prospectus.”

Please note that Item 4 of Form N-1A should summarize how a fund intends to achieve its investment objectives by identifying the Fund’s principal investment strategies. Accordingly, please identify the various segments of the strategy, and explain how each will be managed. Please apply this comment to across the Funds.

Show Raw Text
CORRESP
1
filename1.htm

    Capital Research and Management Company

    333 South Hope Street

    Los Angeles, California 90071-1406

April 9, 2024

Timothy Worthington

U.S. Securities and Exchange Commission

Division of Investment Management

Disclosure Review Office

100 F Street, N.E.

Washington, D.C. 20549-3628

Re:
	     Capital Group New Geography Equity ETF (“New
Geography Equity”)

Initial Registration Statement on Form N-1A

File Nos. 333-276931, 811-23936

Capital Group International Core Equity ETF
(“International Core Equity”)

Initial Registration Statement on Form N-1A

File Nos. 333-276930, 811-23935

Capital Group Global Equity ETF (“Global
Equity”)

Initial Registration Statement on Form N-1A

File Nos. 333-276927, 811-23934

Capital Group Conservative Equity ETF (“Conservative
Equity”)

Initial Registration Statement on Form N-1A

File
Nos. 333-276928, 811-23933

Dear Mr. Worthington:

In response to your comment letter, dated March 6,
2024, to the initial registration statements on Form N-1A (the “Registration Statements”) of New Geography Equity, International
Core Equity, Global Equity  and Conservative Equity  (each, a “Registrant” and together, the “Registrants”),
we hereby file Pre-Effective Amendment No. 1 to the Registration Statements under the Investment Company Act of 1940 (the “1940
Act”) (such amendment, the “Amendment”) pursuant to Rule 472 of the 1933 Act. We appreciate your prompt response to
the filing.

Our responses to your comments are set forth below.
The Amendment reflects additional information that was not contained in the initial Registration Statements.

General

 1. We note that the registration statements are missing information and exhibits and contain bracketed disclosures. We may have comments
on such portions when you complete them in a pre-effective amendment, on disclosures made in response to
this letter, on information supplied supplementally, or on exhibits filed in any pre-effective amendment. Please plan accordingly.

Response: We have updated the Registration Statements in
a pre-effective amendment to address this comment. We will also provide any outstanding information or exhibits in a subsequent pre-effective
amendment. We acknowledge that you may have additional comments.

 2. Please advise us if you have submitted or expect to submit any exemptive applications or no-action requests in connection with the
registration statements.

Response: The Registrants do not presently intend to rely
on any exemptive relief. However, as disclosed in each Registration Statement: “While it has no present intention of doing so, the
fund’s board could determine that it is in the best interests of the fund not to publicly disclose the fund’s complete portfolio
holdings on a daily basis. In such event, and upon prior written notice to shareholders, the fund will be required to rely on exemptive
relief granted by the SEC, or rule or regulation in force at such time, to disclose its full portfolio holdings on a quarterly basis,
similar to mutual funds.” We confirm supplementally that an application was filed on April 30, 2021, and amended on August 25, 2021,
for an order under Section 6(c) of the 1940 Act for an exemption from Sections 2(a)(32), 5(a)(1), 22(d) and 22(e) of the 1940 Act and
Rule 22c-1 under the 1940 Act, and under Sections 6(c) and 17(b) of the 1940 Act for an exemption from Sections 17(a)(1) and 17(a)(2)
of the 1940 Act, and under Section 12(d)(1)(J) of the 1940 Act for an exemption from Sections 12(d)(1)(A) and 12(d)(1)(B) of the 1940
Act. If and when granted, such relief would allow the Registrants flexibility to convert to a less transparent fund structure (in each
case subject to board approval and prior written notice to shareholders), which would allow the Registrants to disclose their portfolio
holdings on a quarterly rather than daily basis.

 3. Where a comment is made with regard to disclosure in one location of a registration statement, it is applicable to all similar disclosure
appearing elsewhere in all four registration statements.

Response: We acknowledge this comment and have addressed
the comments accordingly.

Capital Group New Geography Equity ETF

Principal Investment Strategies, Page 2

 4. The first sentence of the first paragraph discloses that “The fund invests primarily in common stocks of companies with significant
exposure to countries with developing economies and/or markets [emphasis added]. The securities markets of these countries may
be referred to as emerging markets. [emphasis added].”

 a. Please clarify the disclosure to explain what countries or markets would be considered “developing.”

Response: In keeping with the Staff’s guidance on layered
disclosure, the characteristics of developing countries are described in the fund’s prospectus in the risk factor titled “Investing
in developing countries”, and additional detail is provided in the fund’s statement of additional information in the risk
factor titled “Investing in developing countries”. In addition, the fund’s prospectus includes disclosure of factors
considered by the fund’s investment adviser in determining whether a developing country is a “qualified developing country” for the
fund. For additional clarity, we will also supplement the disclosure of the fund’s principal investment strategies in both the fund’s
summary and statutory prospectuses to include the following disclosure after the description of such factors:

In some cases, a country with a less developed
economy may nevertheless be deemed a developed country by the fund’s investment adviser when assessed using the qualifying factors
described above. In these cases, a country that more closely resembles developed countries relative to other developing countries when
assessed along such criteria may be deemed a developed country. South Korea and Taiwan, for example, are deemed developed countries (and
not qualified developing countries) for purposes of the fund's investment strategy.

 b. Please supplementally explain to the Staff the inclusion of both “markets” and “economies.” Please clarify
the distinction in the disclosure.

Response: To clarify the disclosure, we will update the disclosure
to replace references to “countries with developing economies and/or markets” with references to “developing countries”.

 c. Please clarify if there is a difference between “developing economies and/or markets” and “qualified countries.”

Response: “Qualified countries” are developing
countries that the fund’s investment adviser has determined are “qualified” as described in additional detail in the
“Investment objective, strategies and risks” section of the fund’s statutory prospectus. As a result, certain developing
countries may not be considered a “qualified country” for the fund. To provide additional clarity regarding the difference
between qualified developing countries and nonqualified developing countries, we will supplement the disclosure as follows:

In determining whether a country is a qualified developing country,
the fund’s investment adviser considers such factors as the country’s per capita gross domestic product, the percentage of
the country’s economy that is industrialized, market capital as a percentage of gross domestic product, the overall regulatory environment,
the presence of government regulation limiting or banning foreign ownership, and restrictions on repatriation of initial capital, dividends,
interest and/or capital gains. When assessed along these criteria, a qualified developing country will
generally resemble developed countries more closely relative to nonqualified developing countries.

 d. While the Staff notes the disclosure within the first paragraph that “securities markets in [developing]
countries may be referred to as emerging markets,” please supplementally explain the use of the term, “developing economies
and/or markets” as opposed to “emerging markets.”

Response: To clarify the use of the term, we will update
the disclosure to replace references to “countries with developing economies and/or markets” with references to “developing
countries”. For additional clarity, we will also supplement the quoted disclosure to say “[t]he securities markets of these
countries may be referred to as emerging markets or
frontier markets,” and we will also supplement
the disclosure of the fund’s principal investment strategies in both the fund’s summary and statutory prospectuses to include
the additional disclosure described in our response to Comment 4(a) above.

 e. Please clarify the extent to which the New Geography Equity intends to invest in US issuers that would qualify as eligible for inclusion
in the New Geography Equity’s portfolio.

Response: We confirm supplementally that, while fund may
invest in US issuers, it is not a principal investment strategy of the fund to invest in securities of US issuers. Accordingly, we respectfully
decline to supplement the disclosure as proposed.

 5. Within the third sentence of the first paragraph, New Geography Equity discloses that it will consider any company for
                                                                investment regardless of where it domiciled if “a significant portion of the company’s assets or revenues
                                                                (generally [emphasis added] 20% or more) is attributable to developing countries.” Please explain the use of the
                                                                qualifier, “generally”.

Response: We confirm supplementally that 20% is the
threshold generally used for determining whether a significant portion of a company’s assets or revenues is attributable to
developing countries. However, in certain instances, the fund may invest in a company with a different percentage of assets or
revenues attributable to developing countries when the fund’s investment adviser determines such percentage should be
appropriately considered a significant portion of the company’s assets or revenues based on the specific facts and
circumstances. As a result, we have included the qualifier “generally” in this disclosure.

 6. The first sentence of the second paragraph discloses that New Geography Equity invests at least 30% of its assets in equity securities
of issuers domiciled in qualified countries that have developing economies. Furthermore, the third paragraph, states that, “In determining
whether a country is qualified, the fund’s investment adviser considers such factors as [emphasis added] the country’s
per capita gross domestic product, the percentage of the country’s economy that is industrialized, market capital as a percentage
of gross domestic product, the overall regulatory environment, the presence of government regulation limiting or banning foreign ownership,
and restrictions on repatriation of initial capital, dividends, interest and/or capital gains. The fund’s investment adviser maintains
a list of qualified countries and securities in which the fund may invest.”

 a. Please disclose all factors the adviser considers in determining what constitutes a qualifying country.

Response: We confirm supplementally that the factors disclosed
in the prospectus are the primary factors considered in determining whether a country is a qualifying country. However, we do not believe
it is reasonable or necessarily helpful to investors to list all possible factors that might be relevant to the determination of whether
a particular country is a qualifying country. Accordingly, we respectfully decline to supplement the disclosure as proposed.

 b. Please disclose which countries the adviser considers “qualifying.”

Response: The list of qualified countries is included in
the section captioned “Investment objectives, strategies and risks” in the fund’s statutory prospectus. Such list is
only included in the statutory prospectus in accordance with the Staff’s guidance that disclosure in response to Item 4 of Form N-1A should summarize the
more fulsome disclosure in Item 9 of Form N-1A. Accordingly, we respectfully decline to supplement the disclosure as proposed.

 c. The Staff notes that New Geography Equity lists some of the countries it will invest in within the Statutory Prospectus. Please include
a list of all countries New Geography Equity will invest in within the Summary Strategy section.

Response: As described above, the list included in the statutory
prospectus is a list of “qualified” countries. However, the fund may invest in securities of issuers domiciled in any country,
including developed countries, as described in the fund’s prospectus and statement of additional information. As a result, we do
not believe it is reasonable or necessarily helpful to investors to list all countries in which the fund may invest. We further believe
that the list of qualified countries is appropriately disclosed in the statutory prospectus rather than the summary, in keeping with longstanding
staff guidance on layered disclosure. Accordingly, we respectfully decline to supplement the disclosure as proposed. However, to provide
additional clarity, we will revise the description of the list of qualified countries in the fund’s statutory prospectus as follows:

As of [May 1], 2024, the Qqualified
developing countries in which the fund may invest currently include, but are not limited to, are
Argentina, Bahrain, Bangladesh, Belarus, Belize, Bolivia, Botswana, Brazil, Bulgaria, Chile, China, Colombia, Costa Rica, Croatia,
Czech Republic, Dominican Republic, Ecuador, Egypt, El Salvador, Estonia, Gabon, Ghana, Greece, Hungary, India, Indonesia, Iraq, Jamaica,
Jordan, Kazakhstan, Kenya, Kuwait, Latvia, Lebanon, Lithuania, Macau, Malaysia, Mauritius, Mexico, Morocco, Namibia, Oman, Pakistan, Panama,
Paraguay, Peru, Philippines, Poland, Qatar, Romania, Russian Federation, Saudi Arabia, Serbia, Slovakia, South Africa, Sri Lanka, Thailand,
Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, Uruguay, Venezuela, Vietnam and Zambia.

 7. The second sentence of the second paragraph discloses that “The fund may also, to a limited extent, invest in securities of
issuers domiciled in nonqualified developing countries.” Please explain supplementally the use of the qualifier “to a limited
extent.” Please disclose the specific risks associated with investing in issuers domiciled in such “non-qualifying developing
countries” if such investments will be part of the fund’s principal investment strategies.

Response: The disclosure that the fund will invest in nonqualified
developing countries “to a limited extent” should be read consistent with the plain meaning of such term. The fund does not
expect to invest materially in such countries, and it will not be a part of the fund’s principal investment strategies to invest
in such countries.

 8. Please consider redrafting the order of disclosure in the Summary Strategy Section to disclose 1) the 80% test in equities, 2) New
Geography Equity’s principal exposure to issuers with significant exposure to developing countries, 3) the 30% investment in issuers
domiciled in qualifying countries, 4) and the limited exposure to issuers in non-qualifying countries.

Response: We will redraft the order of disclosure as requested.

 9. The fourth paragraph discloses that, “The investment adviser uses a system of multiple portfolio managers in managing assets.
Under this approach, a portfolio is divided into segments managed by individual managers. For more information
regarding the investment process of the fund, see the ‘Management and organization’ section of this prospectus.”

Please note that Item 4 of Form N-1A should summarize how a fund
intends to achieve its investment objectives by identifying the Fund’s principal investment strategies. Accordingly, please identify
the various segments of the strategy, and explain how each will be managed. Please apply this comment to across the Funds.