ACTIVE ETFs: THE NEXT ACT - BNY Mellon

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ACTIVE ETFs: THE NEXT ACT - BNY Mellon
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ACTIVE ETFs:
THE NEXT ACT
BY BEN SLAVIN
BY THE
NUMBERS
$9.35 TRILLION
Worldwide assets invested in global exchange-traded
funds and products1

$400 BILLION
Worldwide assets invested in actively managed ETFs
and ETPs2

152.5 PERCENT
Growth of worldwide assets in actively managed ETFs
and ETPs since the end of 20193

4.16 PERCENT
Active ETFs as a share of global ETF assets4

188
Number of new ETFs launched in the U.S. in 20215

66 PERCENT
Active ETFs as a share of 2021 U.S. ETF launches6

$25.3 BILLION
Assets invested in the ARK Innovation ETF, the
largest actively managed ETF7

$15 BILLION
Inflows into the ARK Innovation ETF in the past year8

575.9 PERCENT
Five-year return of the ARK Innovation ETF (ARKK)9

SOURCES:
1.ETFGI Active ETF and ETP Industry Insights,
June 30 2021
2.ETFGI Active ETF and ETP Industry Insights,
June 30 2021
3.ETFGI Active and ETF and ETP Industry Insights,
June 30, 2021
4.ETFGI Active ETF and ETP Industry Insights, May 2021
5.Bloomberg Intelligence, as of June 29, 2021
6.Bloomberg Intelligence, as of June 29, 2021
7.ETF Database, as of July 1, 2021
8.ETF Database, as of July 1, 2021
9.ETF Database, as of June 30, 2021
A BOOM IN ACTIVELY MANAGED ETFS COULD BE
JUST THE START OF A SHIFT IN A $9.4 TRILLION
INDUSTRY THAT HAS LONG BEEN A BASTION OF
INDEX-TRACKING INVESTMENTS.

BY BEN SLAVIN

         nvestors could be forgiven for     jitters, inflation fears, and interest rate   increasingly popular way for savers

I        failing to notice the 2008 debut
         of the first actively managed
         exchange-traded fund (ETF).
  Bear Stearns launched the first ETF
that invested based on the discretion
                                            anxiety. Inflows into actively man-
                                            aged U.S. ETFs in the first six months
                                            of this year topped $55 billion, swiftly
                                            approaching the 2020 full year intake
                                            of $59 billion, according to Morningstar
                                                                                          to stay in the stock market, according
                                                                                          to reports. And companies sitting on
                                                                                          piles of cash are snapping up ultra-
                                                                                          short debt ETFs, trying to offset the
                                                                                          zero-interest drag of money markets
of human money managers instead of          (see Figure 1).                               while minimizing the interest rate risk
tracking an index just one day after J.P.     Currently, the largest of these funds       inherent in longer-term bonds.
Morgan Chase & Co. upped its firesale       is the ARK Innovation ETF (ARKK), the           “Investors out there finally get it,”
bid to buy the beleaguered investment       flagship fund from ARK Investment             said Ben Johnson, director of global
firm. It was an inauspicious beginning:     Management, a boutique asset manager          exchange-traded fund research for
the Bear Stearns Current Yield Fund         run by Cathie Wood. The fund raked in         Morningstar. “‘Active ETF’ is not an
survived for less than a year.              more than $15 billion in new investor         oxymoron. There are a number of
  Since then, market mavens have            cash in the past year to become the           funds that have enough of a track
repeatedly proclaimed the imminence         largest actively managed ETF in the           record to show they can deliver.”
of the long-awaited boom for active         U.S., according to ETF Database. ARK’s
ETFs. This year may finally prove them      other active ETFs are also growing,           PASSIVE LEGACY
right.                                      buoyed by a $17.8 billion haul for the        Since the first ETF launched nearly
  After more than a decade of fits and      full year ended June 30.                      three decades ago, the industry has
starts, active management is gaining          While some investors have been              grown in lockstep with the sort of index
traction in ETFs, an industry long          swept up by the eye-popping gains             tracking strategies championed by the
viewed as nearly synonymous with            of a few thematic funds, others are           late Vanguard founder John C. Bogle.
plain vanilla index investing. Investors    seeking safet y in active manage-             Bogle sometimes criticized the high
are flooding in at a record pace, enticed   ment. Discretionary strategies that           fees charged by many mutual funds,
by triple-digit returns of some funds       use options to limit exposure to stock        whose stock pickers rarely outsmarted
and a potent cocktail of pandemic           market downturns have become an               the market, according to MarketWatch.
“Investors out there finally get it. ‘Active
 ETF’ is not an oxymoron. There are a
 number of funds that have enough of a
 track record to show they can deliver.”
  —BEN JOHNSON, MORNINGSTAR

Bogle suggested that investors could,             three new transparent actively man-         BEHIND THE BOOM
at times, be better off investing in inex-        aged ETFs, including offerings that pro-    The recent surge is owed to a conflu-
pensive funds that mimic diversified              vide unique exposure to remote work         ence of circumstances, including two
benchmarks.                                       technology innovations.                     major regulatory changes that made
  His idea caught on, accelerating                  Last year, the industry also saw the      ETFs far more appealing to would-be
in the wake of the financial crisis. In           long-awaited debut of the first active      issuers. In September 2019, the U.S.
August 2019, assets in passive U.S.               non-transparent ETFs; there are now         Securities and Exchange Commission
equity mutual funds and ETFs over-                three dozen active non-transparent          approved the so-called “ETF Rule,”
took active for the first time, according         ETFs on the market. This year, firms        which standardized the regulations for
to Morningstar.                                   such as Putnam Investments, T. Rowe         launching and operating ETFs. That
  While that trend shows little sign of           Price and Fidelity Investments intro-       same year, the SEC approved the first
an outright reversal, active managers             duced ETF copycats of popular active        active non-transparent ETFs, removing
are clawing back some ground. To be               mutual funds, including an ETF ver-         a major hurdle that had kept many
sure, active ETFs remain a small piece            sion of the $27 billion Fidelity Magellan   active managers on the sidelines.
of the $9.4 trillion global ETF industry,         fund. Vanguard, meanwhile, launched           “The ETF Rule leveled the playing
accounting for roughly 4.2% of assets,            its first actively managed bond ETF.        field,” said Stephanie Pierce, chief
according to ETFGI, an independent                  In March, Guinness Atkinson Asset         executive officer of ETF, index and cash
research and consulting firm. But that            Management completed the first ever         investment strategies for BNY Mellon
may be changing. Worldwide assets                 conversion of mutual funds into ETFs.       Investment Management.
in active ETFs have more than dou-                Dimensional Fund Advisors followed            BNY Mellon has filed a registration
bled since the end of 2019, ETFGI data            suit in June, converting four actively      statement with the SEC to add the first
show.                                             managed mutual funds into ETFs,             active fund to its ETF lineup, an ultra-
  “This year is really the year that              bringing over roughly $30 billion in        short fixed income fund. Ultra-short
we’re seeing net flows into active pick           assets. It was the largest conversion to    and short-term debt funds have been
up,” said Deborah Fuhr, founder and               date, and instantly made DFA one of         one of the most popular segments of
managing partner of ETFGI.                        the 15 largest ETF issuers. So far this     the active ETF market, according to a
  A s s e t m a n a ge r s h ave a c c e l e r-   year, actively managed ETFs account         NASDAQ report, as the prolonged era of
ated their active activity, staking out           for nearly 66% of new ETF launches          near-zero interest rates has asset man-
new territory in ETFs. In October,                in the U.S., a record, according to data    agers and corporate treasurers hunting
BlackRock’s iShares unit launched                 from Bloomberg (see Figure 2).              for safe ways to boost yields.
ACTIVE INGREDIENTS
                                 Net flows into actively managed U.S. ETFs have surged.

                                 20 Billion

                                 15 Billion
MONTHLY INFLOWS (U.S. DOLLARS)

                                 10 Billion

                                 5 Billion
                                             08

                                                           09

                                                                       10

                                                                                 11

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                                 5 Billion

                                                                                                                                        SOURCE:MORNINGSTAR INC., DATA AS OF MAY 31, 2021
                                 FIGURE 1

                                 SPECIAL INTEREST
                                 Launches of new active exchange-traded funds are on track for a record-breaking year.

                                 350

                                 300

                                                         TOTAL ETF LAUNCHES

                                 250

                                                         ACTIVE ETF LAUNCHES
                                 200

                                 150

                                 100
                                                                                            *Cathie Wood debuts ARK’s first active ETF

                                  50

                                    0

                                                  2011          2012        2013           2014         2015          2016         2017          2018             2019          2020        YTD 2021

                                 FIGURE 2                                                                                                                                    SOURCE: BLOOMBERG LP
FUTURE FOR ACTIVE
     An increasing proportion of investors say they plan to raise their exposure to
     actively managed ETFs.

           7%                28%                                                                            59%                 5%
21
20

          6%         19%                                                                                      75%
20
20

                                                                                                   75%                           100%
     0%                              25%                             50%

      INCREASE BY MORE THAN 20%        INCREASE BY 5% TO 20%      NO CHANGE      DECREASE BY 5% TO 20%     DECREASE BY MORE THAN 20%

                                                                                SOURCE: JPMORGAN, TRACKINSIGHT GLOBAL ETF SURVEY 2021
     FIGURE 3

          This year, BNY Mellon also plans         has already risen from 4% to 14% (see        ETF space.” The following year, State
     to make ETFs from several fund                Figure 4).                                   Street partnered with private equity
     companies available through its                  “I was surprised — I still am — how       firm Blackstone Group to launch the
     short- end investments platform,              long it has taken for active [ETFs]          SPDR Blackstone Senior Loan ETF, an
     LiquidityDirectsm.                            to catch on,” said John Southard,            actively managed senior loan strategy.
          “Our clients are taking a more           co-founder of PowerShares Capital            In 2015, State Street launched the SPDR
     sophisticated view in terms of how            Management, and now co-founder and           DoubleLine Total Return Tactical ETF.
     they manage cash,” said Pierce. “I think      chief investment officer of Innovator,       The fund, managed by Gundlach’s
     we’re going to see more clients who           another ETF shop.                            DoubleLine Capital, was one of the
     used prime money markets in the past             It wasn’t until PIMCO, a leading          fastest growing ETFs of the year.
     start to use ultra-short-term alongside,      name in fixed-income investment man-           MINT proved to be a long-lasting suc-
     or in place of, prime funds.”                 agement, launched an ETF version of          cess, reigning as the largest active ETF
                                                   its popular short-term debt strategy         on the market for more than a decade.
     SLOW START                                    in 2009 that active ETFs gained real         Today, that honor goes to ARKK.
     The very first ETF — the SPDR S&P 500         traction. The PIMCO Enhanced Short
     ETF Trust — debuted in 1993, but it took      Maturity Active Exchange-Traded              TAKING OFF
     another 15 years before the first actively    Fund, which trades under the ticker          “The biggest reason active manage-
     managed ETF reached the market.               MINT, c apit alized on post- c ri si s       ment is taking off is Cathie Wood,” said
          After the 2008 Bear Stearns debut,       demand for higher yields.                    Eric Balchunas, senior ETF analyst at
     other firms quickly followed suit.               “When PIMCO launched MINT, that           Bloomberg Intelligence. “She really
     PowerShares, now part of Invesco,             was a game changer for active ETFs,”         showed how investor demand can be
     launched an active fixed income ETF           said Todd Rosenbluth, senior director        there.”
     as well as the first active equity ETFs.      of ETF and mutual fund research at             Wood, ARK’s founder and chief
          Some 54% of respondents to a survey      CFRA, a research firm.                       investment officer, began her career as
     from J.P. Morgan and TrackInsight said           Like MINT, the most successful active     an assistant economist for The Capital
     they are invested in active ETFs today,       ETFs piggybacked off the reputation of       Group before taking a job with Jennison
     up from 31% a year earlier, with 35%          marquee managers like Bill Gross or Jeff     Associates. She spent 18 years with the
     saying they would increase their expo-        Gundlach. When PIMCO introduced an           firm in various roles, including chief
     sure over the next few years (see Figure      ETF version of its Total Return Bond         economist, equity research analyst,
     3). The share of investors with an expo-      Fund in 2012, it was touted by CNN as        portfolio manager and director. She
     sure of more than 20% to active ETFs          “a litmus test for the actively managed      went on to co-found a hedge fund,
HAVE AND HOLD
                                                            Investors have increased their exposure to actively managed ETFs.

                                                            88%

                                                                     2020       2021
Percentage of portfolio invested in actively-managed ETFs

                                                            70%

                                                            53%

                                                            35%

                                                            18%

                                                             0%
                                                                         None                  1%-5%            6%-10%               11%-20%             21%-30%                   More than
                                                                                                                                                                                       40%

                                                            FIGURE 4                                                                   SOURCE: JPMORGAN, TRACKINSIGHT GLOBAL ETF SURVEY 2021

                                                            Tupelo Capital, in 1997 before moving       published white papers, hosted pod-          market segments such as work-from-
                                                            to AllianceBernstein, where she spent       casts, and became a regular guest on         home technology, e-commerce, and
                                                            12 years as chief investment officer of     financial news shows. She sent out reg-      genomics — all areas that ARK has spe-
                                                            global thematic strategies, managing        ular emails about her trades and publi-      cialized in for years, Leggi said. “As a
                                                            more than $5 billion. Her experience        cized her stock picks on Twitter.            result of the pandemic, we’ve seen
                                                            taught her to pay attention to ideas that     ARK’s first three years were a             an acceleration of the adoption of the
                                                            other investors ignored.                    struggle. In 2015, ARK’s ETFs took in        technologies that we’re investing in,”
                                                              After AllianceBernstein, Wood went        a paltry $17 million combined. Her           Leggi added.
                                                            out on her own. She founded ARK             fortunes began to turn in 2017 when            W h i l e t h e f i r m’s f l a g sh i p E T F
                                                            Investment Management in January            two of her ETFs were among the top           returned triple digits in 2020, investors
                                                            2014. Nine months later, she launched       performers for the year. Since then,         shouldn’t expect those kinds of gains
                                                            ARK’s first actively managed ETFs.          the firm’s flagship fund has continued       every year, he said. The firm aims for a
                                                              At the time, many stock pickers           to beat the market. Through June 30,         15 percent annualized return, but per-
                                                            were put off by the transparency of         ARKK returned nearly 576 percent             formance can be volatile year to year,
                                                            ETFs. Unlike mutual funds, the vast         in the past five years, 191.6 percent        Leggi said.
                                                            majority of ETFs must disclose their        in the past three, and 73.7 percent            Two actively managed thematic
                                                            holdings every day — an anathema for        in the past year, according to ETF           funds from Amplify ETFs delivered tri-
                                                            stock pickers who jealously guard their     Database.                                    ple-digit returns in the past year. Both
                                                            trading secrets. By opening their books,      ARK’s suite of active ETFs has grown       funds handily outperformed their
                                                            money managers ran the risk that copy-      increasingly popular because the             index-tracking rivals because their port-
                                                            cats could muscle in on their best ideas.   appetite for investing in technological      folio managers can buy and sell stocks
                                                              Instead of shying away from trans-        innovation has expanded, said Renato         more nimbly than benchmark-bound
                                                            parency, Wood embraced it. She made         Leggi, client portfolio manager for ARK.     competitors, said Christian Magoon,
                                                            ARK’s investment research public. She       The pandemic also boosted interest in        founder and CEO of Amplify ETFs. By
ACTIVE BY ASSET CLASS
Fixed income counts for the largest slice of assets in exchange traded funds and products worldwide.
                                          3%
                               4%         COMMO-
                                          DITIES
                               MIXED
                                                                                                           FIXED INCOME

                                                                                                           EQUITY

                                                                                                           MIXED

                                                                                                           COMMODITIES

                                                                                                           ALTERNATIVE

                   35%                                                                                     CURRENCY

                   EQUITY                                     58%
                                                              FIXED INCOME

                                                                                                    SOURCE:   ETFGI; DATA AS OF MAY 2021

FIGURE 5

eschewing an index, Amplify’s active                 “People still have wealth protec-         FIXED INCOME
ETFs can also invest in IPOs and some              tion on their minds,” said Southard,        While thematic and defensive strategies
of the smallest companies that would               Innovator’s CIO. “It’s hard to invest       are gaining ground, fixed income is by
be hard to make room for in a passive              without thinking about protection           far the largest segment of the active ETF
strategy, he added.                                when stocks are at all-time highs.”         marketplace. Fixed income ETFs have
  “These are strategies that require                 Another active options strategy that's    grown rapidly in recent years as institu-
you to be opportunistic and dynamic,               garnering interest is the Quadratic         tional investors, traders, insurers, and
and that’s hard to write into index                Interest Rate Volatility and Inflation      corporate treasurers have added ETFs
rules,” Magoon said.                               Hedge ETF, run by Nanc y Davis,             to their fixed income holdings.
                                                   founder and CIO of Quadratic Capital          Active management has had a firm
ACTIVE DEFENSE                                     Management LLC. The fund seeks to           foothold in the ETF marketplace since
Not every investor has been drawn to               protect purchasing power and uses an        the advent of MINT. And for good
active ETFs because of a few hot the-              actively managed portfolio of options       reason: Fixed income has proven to be
matic funds. Actively managed defen-               and inflation-protected Treasuries to       an asset class where active managers
sive strategies have also been a popular           profit from the steepening yield curve.     have a decent track record of beating
way to counter market uncertainty.                 In the two years since its debut, the       their indexed rivals, said Morningstar’s
  Innovator’s three-year-old suite                 fund has grown to $3.4 billion in assets.   Johnson. Roughly 58% of the assets
of defined outcome ETFs, which use                   Exchange-traded commodity prod-           invested in active ETFs worldwide is in
options to protect investors against               ucts have also gained ground as inves-      fixed-income funds, according to ETFGI
market downturns, don’t have the                   tors try to hedge their portfolio against   (see Figure 5).
same kind of discretionary strategy, but           inflation in raw materials prices. For        One particularly popular segment
they are nonetheless part of the active            example, an actively managed com-           has been short-term and ultra-short-
ETF marketplace. The funds took in                 modit y ETF from Invesco gained             term debt funds. The JPMorgan Ultra
$1.4 billion in 2020, and another $771             $2.3 billion in inflows in the first half   Short Income ETF has taken in $4.6
million in the first half of this year.            of 2021.                                    billion in the past year, growing to
“Active man­agers have long felt that daily
  transpar­ency could eat into performance.
  With the new non-transparent offerings
  those concerns can be largely put to rest.”

 — JC MAS, BNY MELLON

more than $17 billion. It’s now the         their active roster.                        With the new non-transparent offer-
second largest active ETF after the ARK       “Given the assets in active mutual        ings, those concerns can be largely
Innovation ETF, just ahead of MINT.         funds, we’re still in the first inning      put to rest.”
  The BNY Mellon Ultra Short Income         for active ETFs,” said Brandon Clark,         The key to success in active manage-
ETF, expected to launch in August this      direc tor of the ETF business for           ment is understanding what investors
year and trade under the ticker BKUI,       Federated Hermes Inc., an active            are looking for, said Balchunas, the
will be sub-advised by Dreyfus Cash         investing firm with $625 billion under      Bloomberg analyst. So-called closet
Investment Strategies, BNY Mellon's         management. Federated, which has yet        indexers, who are technically active
affiliated money market business and        to launch an ETF, plans to introduce its    but stick fairly close to the index, will
the eighth largest money market fund        own suite of active ETFs later this year,   have a hard time standing out, espe-
sponsor in the U.S.                         Clark said.                                 cially if they’re charging higher fees,
  “The yield environment is absolutely        Today, there are roughly three dozen      he said, but when it comes to niche
the driver,” Pierce said. “What we’re       non-transparent ETFs on the market,         active strategies like those offered by
seeing is that clients are struggling for   though uptake has been slow, said           ARK and Amplify, investors are much
yield, but they don’t want the volatility   Johnson. So far, only five have amassed     less price- sensitive.
of the longer-term bond funds.”             more than $100 million in assets, a           “Benchmark huggers who play it
                                            crucial threshold that demonstrates         safe aren’t going to win investors,”
THE FUTURE OF ACTIVE                        the viability of an ETF and helps funds     Balchunas said. “Investors want either
The big question is whether the recent      gain access to distribution platforms,      dirt cheap or shiny objects. They’ve
boom in active ETFs is a performance        he added.                                   got the boring base of vanilla, and they
chasing blip, or a lasting commitment         But the active non-transparent space      want a pop of active on top.”
to active on the part of both ETF inves-    should continue to grow as money
tors and issuers. Money managers            managers find new ways to wrap their
are clearly hoping there’s still room       trading strategies into an ETF, said JC     Ben Slavin is head of ETF Services for BNY
for growth. In addition to the ultra-       Mas, head of equity and ETF trading for     Mellon.
short term debt ETF, BNY Mellon has         BNY Mellon.                                 Questions or comments? Contact jeremy.
several other actively managed ETFs           “The ETF structure is a more effi-        kross@bnymellon.com, ron.hooey@
in registration, SEC records show.          cient vehicle,” Mas said. “Active man-      bnymellon.com, or matthew.camuso@
Other firms are also gearing up to          agers have long felt that daily trans-      bnymellon.com, or reach out to your usual
enter the active market, or to expand       parency could eat into performance.         relationship manager.
BNYMELLON.COM

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and is a swap dealer member of the National Futures              09, France (registration number (SIREN) Nr. 538 228 420           provide legal, tax, accountinginvestment, financial or other
Association (NFA ID 0420990).][1]Please contact your BNY         RCS Paris - CIB 13733).                                           professional advice on any matter. This material does not
Mellon representative for services available outside the                                                                           constitute a recommendation or advice by BNY Mellon of
United States and the United Kingdom.                            The Bank of New York Mellon SA/NV operates in Italy               any kind. Use of our products and services is subject to
                                                                 through its Milan branch at Via Mike Bongiorno no. 13,            various regulations and regulatory oversight. You should
BNY Mellon is the corporate brand of The Bank of New             Diamantino building, 5th floor, Milan, 20124, Italy. The          discuss this material with appropriate advisors in the
York Mellon Corporation and may be used as a generic term        Bank of New York Mellon SA/NV, Milan Branch is subject            context of your circumstances before acting in any manner
to reference the corporation as a whole and/or its various       to limiteed additional regulation by Banca d’Italia - Sede di     on this material or agreeing to use any of the referenced
group entities. This material and any products and services      Milano at Divisione Supervisione Banche, Via Cordusio no.         products or services and make your own independent
may be issued or provided under various brand names of           5, 20123 Milano, Italy (registration number 03351).               assessment (based on such advice) as to whether the
BNY Mellon in various countries by duly authorized and                                                                             referenced products or services are appropriate or suitable
regulated subsidiaries, affiliates, and joint ventures of BNY    The Bank of New York Mellon SA/NV operates in Denmark             for you. This material may not be comprehensive or up
Mellon, which may include any of those listed below:             as The Bank of New York Mellon SA/NV, Copenhagen                  to date and there is no undertaking as to the accuracy,
                                                                 Branch, filial af The Bank of New York Mellon SA/NV,              timeliness, completeness or fitness for a particular purpose
The Bank of New York Mellon, a banking corporation               Belgien, and has its registered office at Strandvejen 60/5,       of information given. BNY Mellon will not be responsible
organized pursuant to the laws of the State of New York,         2900 Hellerup, Denmark. It is subject to limited additional       for updating any information contained within this material
whose registered office is at 240 Greenwich St, NY, NY           regulation by the Danish Financial Supervisory Authority          and opinions and information contained herein are subject
10286, USA. The Bank of New York Mellon is supervised            (Finanstilsynet, Århusgade 110, 2100 København Ø).                to change without notice. BNY Mellon assumes no direct
and regulated by the New York State Department of                                                                                  or consequential liability for any errors in or reliance upon
Financial Services and the US Federal Reserve and is             The Bank of New York Mellon SA/NV operates in England             this material.
authorized by the Prudential Regulation Authority (“PRA”)        through its London branch at 160 Queen Victoria Street,
(Firm Reference Number: 122467).                                 London EC4V 4LA, UK, registered in England and Wales              This material, which may be considered advertising, is for
                                                                 with numbers FC029379 and BR014361. The Bank of New               general information purposes only and is not intended to
The Bank of New York Mellon operates in the UK through           York Mellon SA/NV, London branch is authorized by the             provide legal, tax, accounting, investment, financial or
its London branch (UK companies house numbers                    ECB (address above) and subject to limited regulation by          other professional advice on any matter. This material does
FC005522 and BR000818) at One Canada Square, London              the FCA (address above) and the PRA (address above).              not constitute a recommendation or advice by BNY Mellon
E14 5AL and is subject to regulation by the Financial                                                                              of any kind. Use of our products and services is subject to
Conduct Authority (“FCA”) at 12 Endeavour Square,                Regulatory information in relation to the above BNY Mellon        various regulations and regulatory oversight. You should
London, E20 1JN, UK and limited regulation by the PRA at         entities operating out of Europe can be accessed at the           discuss this material with appropriate advisors in the
Bank of England, Threadneedle St, London, EC2R 8AH, UK.          following website: https://www.bnymellon.com/RID.                 context of your circumstances before acting in any manner
Details about the extent of our regulation by the PRA are                                                                          on this material or agreeing to use any of the referenced
available from us on request.                                    The Bank of New York Mellon, Singapore Branch, is subject         products or services and make your own independent
                                                                 to regulation by the Monetary Authority of Singapore. The         assessment (based on such advice) as to whether the
The Bank of New York Mellon SA/NV, a Belgian limited             Bank of New York Mellon, Hong Kong Branch (a branch of a          referenced products or services are appropriate or suitable
liability company, registered in the RPM Brussels with           banking corporation organized and existing under the laws         for you. This material may not be comprehensive or up
company number 0806.743.159, whose registered                    of the State of New York with limited liability), is subject to   to date and there is no undertaking as to the accuracy,
office is at 46 Rue Montoyerstraat, B-1000 Brussels,             regulation by the Hong Kong Monetary Authority and the            timeliness, completeness or fitness for a particular purpose
Belgium, authorized and regulated as a significant credit        Securities & Futures Commission of Hong Kong.                     of information given. BNY Mellon will not be responsible
institution by the European Central Bank (“ECB”) at                                                                                for updating any information contained within this material
Sonnemannstrasse 20, 60314 Frankfurt am Main, Germany,           For recipients of this information located in Singapore: This     and opinions and information contained herein are subject
and the National Bank of Belgium (“NBB”) at Boulevard de         material has not been reviewed by the Monetary Authority          to change without notice. BNY Mellon assumes no direct
Berlaimont/de Berlaimontlaan 14, 1000 Brussels, Belgium,         of Singapore.                                                     or consequential liability for any errors in or reliance upon
under the Single Supervisory Mechanism and by the                                                                                  this material.
Belgian Financial Services and Markets Authority (FSMA)          For clients located in Australia:
at Rue du Congrès/Congresstraat 12-14, 1000 Brussels,            The Bank of New York Mellon is exempt from the                    This material may not be distributed or used for the
Belgium for conduct of business rules, and is a subsidiary       requirement to hold, and does not hold, an Australian             purpose of providing any referenced products or services
of The Bank of New York Mellon.                                  financial services license as issued by the Australian            or making any offers or solicitations in any jurisdiction or
                                                                 Securities and Investments Commission under the                   in any circumstances in which such products, services,
The Bank of New York Mellon SA/NV operates in Ireland            Corporations Act 2001 (Cth) in respect of the financial           offers or solicitations are unlawful or not authorized, or
through its Dublin branch at Riverside II, Sir John              services provided by it to persons in Australia. The              where there would be, by virtue of such distribution, new
Rogerson's Quay Grand Canal Dock, Dublin 2, D02KV60,             Bank of New York Mellon is regulated by the New York              or additional registration requirements.
Ireland and is registered with the Companies Registration        State Department of Financial Services and the US
Office in Ireland No. 907126 & with VAT No. IE 9578054E.         Federal Reserve under Chapter 2 of the Consolidated               Any references to dollars are to US dollars unless specified
The Bank of New York Mellon SA/NV, Dublin Branch is              Laws, The Banking Law enacted April 16, 1914 in the               otherwise.
subject to limited additional regulation by the Central          State of New York, which differs from Australian laws.
Bank of Ireland at New Wapping Street, North Wall Quay,                                                                            This material may not be reproduced or disseminated in
Dublin 1, D01 F7X3, Ireland for conduct of business rules        The Bank of New York Mellon has various other branches            any form without the prior written permission of BNY
and registered with the Companies Registration Office in         in the Asia-Pacific Region which are subject to regulation by     Mellon. Trademarks, logos and other intellectual property
Ireland No. 907126 & with VAT No. IE 9578054E.                   the relevant local regulator in that jurisdiction.                marks belong to their respective owners.

The Bank of New York Mellon SA/NV is trading in Germany          The Bank of New York Mellon Securities Company Japan              The Bank of New York Mellon, member of the Federal
through its Frankfurt branch “The Bank of New York               Ltd, as intermediary for The Bank of New York Mellon.             Deposit Insurance Corporation (“FDIC”).
Mellon SA/NV, Asset Servicing, Niederlassung Frankfurt
am Main”, and has its registered office at MesseTurm,            The Bank of New York Mellon, DIFC Branch, regulated               © 2021 The Bank of New York Mellon Corporation.
Friedrich-Ebert-Anlage 49, 60327 Frankfurt am Main,              by the Dubai Financial Services Authority (“DFSA”) and            All rights reserved.
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