FR 2025-02491

The document is a notice from the Securities and Exchange Commission (SEC), indicating that Venerable Variable Insurance Trust and Venerable Investment Advisers, LLC have submitted an application seeking an exemption from certain regulatory requirements. Specifically, these requirements are part of the Investment Company Act of 1940. The essence of this application is to enable these entities to enter into or amend agreements with subadvisers without needing shareholder approval. Furthermore, the application includes a request to waive certain disclosure obligations related to fees paid to the subadvisers.

Summary of the Document

The notice effectively announces the application for exemptions that could streamline operations for Venerable Variable Insurance Trust and Venerable Investment Advisers. The simplification comes from allowing them to modify arrangements with subadvisers more efficiently, bypassing the typically necessary shareholder approval process. This regulatory flexibility can be crucial for adapting swiftly to market conditions and investment strategies. Additionally, it seeks relief from specific disclosure requirements, potentially making financial disclosures less burdensome for these entities.

Significant Issues or Concerns

There are several concerns intrinsic to this notice:

1. Regulatory Bypass: The exemption request involves bypassing standard procedures that entail shareholder participation and oversight. While this could expedite decision-making for the applicants, it also raises concerns about the reduction of checks and balances typically provided by shareholder input.

2. Legal Complexity: The document is steeped in legal jargon, citing various sections of the Investment Company Act and specific rules under the Securities Exchange Act. This complexity might hinder understanding for individuals not versed in securities law.

3. Accessibility: The detailed process outlined for requesting a hearing or participating in the review process may seem daunting to those unfamiliar with legal processes, potentially discouraging public participation.

Impacts on the Public and Stakeholders

Broad Public Impact:

For the general public, the immediate impact of such regulatory exemptions might not be palpable. However, the precedent it sets in reducing shareholder involvement could foster a broader debate about transparency and investor rights in financial matters. While it may enhance operational efficiency for some entities, the public interest lies in balancing such efficiencies with adequate oversight and accountability.

Impact on Specific Stakeholders:

1. Venerable Variable Insurance Trust and Advisers: These entities stand to benefit significantly from the exemption. They could see faster turnaround times in adjusting their subadvisory relationships, potentially innovating and adapting more readily to market demands without the delay that shareholder approval processes can entail.

2. Shareholders and Investors: For investors, this move might be seen both positively and negatively. On the one hand, streamlined processes could lead to better-managed funds. On the other hand, diminished shareholder involvement might suggest less transparency and fewer opportunities to influence company strategy on significant matters.

3. Regulatory Environment: Regulatory bodies and advocacy groups may view these exemptions as critical tests of the balance between operational flexibility and regulatory rigor. How these exceptions are managed and the outcomes they produce could influence future regulatory practices and policies.

In conclusion, while this notice primarily concerns regulatory exemptions, it prompts broader discussions about governance, fiduciary responsibilities, and the evolving landscape of financial regulation. Its impacts, largely determined by how these exemptions are implemented and overseen, remain to be seen.