October 8, 2025
What happened?
The Securities and Exchange Commission (“SEC”) issued a notice to Dimensional Fund Advisors on September 29, 2025, granting their request to combine mutual funds and ETFs into a single investment vehicle, pending regulatory review. “Interested persons” can issue a request for a hearing until 15 days after the notice is published in the Federal Register.
Over 70 fund companies are currently awaiting approval from the SEC for this multi-share class structure. If approved, this could change how investment products are structured and offered.
Currently, Vanguard is the only company approved to use this fund structure, as it utilizes a dual-class structure for ETF shares of its index mutual funds, with certain limitations. Vanguard has now filed with the SEC for approval to add share classes to its active funds.
According to an Ignites article, SEC staff held a virtual meeting following the notice approval, where “SEC Attorney Trace Rakestraw explained to listeners that applicants looking for approval for dual-share-class funds quickly should make their filings ‘substantially the same’ as Dimensional.” Going on to say that “those asking for different relief than Dimensional’s application may still be granted approval, but would be operating on a far longer timeline.”
What does this mean for me?
Many funds are moving to file for exemption or adapt previous exemption applications to align with Dimensional’s filing. FilePoint has assisted firms with filing their applications with the SEC and is prepared to assist with any additional filings needed.
Additionally, entities looking to enter the ETF space for the first time with new dual share classes should be prepared to adopt the ETF website data requirements pursuant to Rule 6c-11. FilePoint provides ETF data website services utilizing automated data feeds and would be happy to share more information upon request.
