April 2019 Since 2014, direct indexing has been thought of as a potential threat over the ETF industry, but only recently has it become more prevalent. Direct indexing has many advantages that have come to the forefront in recent years: enhancements in portfolio construction, tax harvesting and the demand for passive products. Though these are […]

October 1, 2018 Via E-mail [rule-comments@SEC.gov] Mr. Brent J. Fields Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-1090 Re:  Release Nos. 33-10515 and IC-33140 (File No. S7-15-18): Exchange-Traded Funds; Proposed Rule Dear Mr. Fields: Thank you for the opportunity to submit this letter in response to the request for comments […]