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I'm looking forward to be working alongside my Affiliate Partners. Portfolio Affiliates We do not anticipate that there will be any costs associated with the amendments to rules 17a-6 and 17d-1 d 5 , other than a cost associated with the provision that a fund's board of directors may find that an interest is not material and hence not a "financial interest.
The last thing we want is to be bombarded with our own popups and banners. So, to get around this, we have one simply banner on the right hand side of the page and we affiliate ourselves with the better share trading affiliate programs and forex affiliate programs out there. However, as owners of several financial sites before this one, we have been around the block. We have used countless CFD affiliate programs and have had good experiences and bad. As a result we can help to make life easier for you, pointing you towards the very best forex affiliate programs.
Below we have listed the ones that we have had the best experiences with, along with tips on how to get more from them.
Best Forex Affiliate Program: They can be very picky with regards to the first review of theirs that you place on your site, insisting on specific terms being mentioned. You can also click the image above. This will take you direct to the affiliate page where you can input your details and go through the process. They will require certain things and these may be frustrating.
We had a few minor problems in the beginning but we were then given a very helpful affiliate manager who has been brilliant throughout. As a result, we would recommend them to anyone. The Terms Bear in mind that your site will need to appeal to non-US customers in order for you to benefit from this Forex affiliate program. Traders from the United States are not allowed to join. So, if you have a predominantly US-based traffic, then it might be wasted on this CFD trading affiliate.
Still, even if you are based in the US yourself but your website visitors are not, you may still be able to join and profit. The process for obtaining such an exemption imposes direct costs on applicants. The application process also produces indirect costs, because funds and their affiliated persons forego beneficial transactions rather than undertake to obtain an exemptive order.
Funds and their affiliated persons may forego transactions either because the anticipated benefit of the transaction does not exceed the cost of obtaining an exemptive order, or because the transaction is time-sensitive, and it is not feasible to obtain an exemptive order quickly enough to permit the transaction to occur. As discussed in the Proposing Release, eliminating direct and indirect costs of filing applications may also reduce factors that discriminate against smaller funds and smaller transactions.
Portfolio Affiliates The amendments to rules 17a-6 and 17d-1 d 5 regarding transactions and joint arrangements with portfolio affiliates may expand the range of possible partners with which funds may enter into transactions and joint arrangements. Funds, their second-tier portfolio affiliates, and their shareholders each may benefit from the transactions and arrangements made possible by the amendments.
By broadening the markets available to both buyers and sellers, rule 17a may permit sellers to obtain more favorable pricing, and may make a wider range of investment options available to buyers. Brokerage Transactions Rule 17e-1 will, under certain circumstances, permit subadvisers and their affiliated persons to receive remuneration when acting as broker for an affiliated fund, without complying with all of the rule's recordkeeping and transaction review requirements.
Our staff estimates that boards of directors of funds that employ affiliated brokers currently spend approximately The amendments to rule 17e-1 may benefit funds and their shareholders by allowing funds to avoid these burdens. Purchases During Primary Offerings Underwritten by Affiliated Subadvisers The amendments to rule 10f-3 may benefit funds by broadening their investment options. The Act prohibits a series of a series company from purchasing securities during an underwriting or selling syndicate of which an adviser to any of the series or affiliated person of such adviser is a member.
By providing that, for purposes of section 10 f and rule 10f-3, a series of a series company is a separate investment company, the proposed amendments to rule 10f-3 could broaden i the investment opportunities available to such funds and ii the range of possible purchasers when a subadviser participates in an underwriting syndicate. Funds, fund shareholders, and subadvisers all may benefit from this change. The Act also does not distinguish between a fund with multiple subadvisers that manage discrete portions of its portfolio, and a fund whose subadvisers manage the portfolio in its entirety.
The amendments to rule 10f-3 that deem separately managed portions of a fund's portfolio to be separate investment companies for purposes of section 10 f and rule 10f-3 may increase the investment opportunities of that type of fund. Quantifying the potential magnitude of these benefits may not be possible. The amendments to the percentage limit of rule 10f-3 also may broaden the investment options available to funds. The Act does not distinguish between purchases by funds or portions of funds that are recommended by a subadviser that is or is an affiliated person of a participant in the underwriting or selling syndicate, and purchases by funds or portions of funds for which other subadvisers provide investment advice.
By providing that the percentage limit of rule 10f-3 applies only to purchases by funds, portions of funds, and accounts for which participants provide investment advice, the amendments to rule 10f-3 may increase the investment opportunities of a fund with multiple subadvisers that manage discrete portions of its portfolio. The amendments to the percentage limit may reduce the cost of complying with rule 10f-3 because purchases made by funds that are not advised by participants in the underwriting or selling syndicate will no longer need to be aggregated with purchases made by funds that are advised by advisers that are participants in the underwriting.
Because multiple advisers will no longer be required to coordinate their actions, the amendment may make it easier to ensure compliance with the rule, and less expensive to collect and compile the relevant information. Ownership of Securities Issued by Subadvisers Similarly, the amendments to rule 12d may also benefit funds by broadening their investment options.
Amending rule 12d to permit a fund to acquire securities issued by one of its subadvisers, or an affiliated person of one of its subadvisers, when the subadviser is not in a position to influence the decision by the fund to purchase the securities, may increase the investment opportunities of these funds. Costs The Commission anticipates that funds, their shareholders, and their advisers and other affiliated persons may incur certain costs, including certain direct costs from complying with the new rule and amendments.
The exemptions resulting from today's rulemaking also may encourage shifts in market behavior that could create direct and indirect costs for certain entities. Furthermore, the exemptions may allow funds to proceed with disadvantageous transactions that existing restrictions would have prevented. Portfolio Affiliates We do not anticipate that there will be any costs associated with the amendments to rules 17a-6 and 17d-1 d 5 , other than a cost associated with the provision that a fund's board of directors may find that an interest is not material and hence not a "financial interest.
Based on discussions with industry representatives, our staff estimates that reviewing the materiality of a Prohibited Participant's interest in a party to the transaction and recording the basis for those findings would require approximately We assume that if the cost of holding such a meeting exceeds the benefit to the fund, the fund will either forego the opportunity to engage in the transaction or require the Prohibited Participant to divest itself of its interest.
Subadvisory Affiliates A fund and its advisers and subadvisers may incur costs in complying with the requirements of rule 17a and amended rules 10f-3, 12d, and 17e-1 that partially offset the benefits of these rules. In order for a fund to rely on the exemptions in the rule and amendments, the fund's advisory contracts must include certain provisions that they may not currently include.
Because such contracts generally are subject to renewal at regular intervals, adding such provisions may not entail additional administrative costs. As discussed above, we do not view the required changes to subadvisory contracts to be material for purposes of section 15 of the Investment Company Act and, as a result, funds will not have to obtain shareholder approval of the change. By exempting the commissions paid to certain affiliated subadvisers from the requirement for scrutiny by the board of directors, rule 17e-1 may allow a rise in brokerage commissions that the fund pays.
Whether this increased cost occurs will depend on the extent to which the scrutiny currently required of boards of directors has resulted in findings that commissions to be paid by funds are excessive. Although we requested comment on the frequency of boards of directors making such findings, we received no comments on this issue.
The amendments to rule 10f-3 may encourage division of funds into discrete parts managed by multiple subadvisers. A fund that is advised by subadvisers that participate, or are affiliated with persons that participate, in underwriting syndicates may have an incentive to reorganize in order to take advantage of the opportunity to have a part of the fund purchase securities during the syndicate.
Likewise, a fund that is advised by a subadviser that participates in underwriting syndicates may have an incentive to reorganize in order to comply with the percentage limit of rule 10f-3 and take advantage of the opportunity to purchase securities in reliance on that rule's exemption. Such a development would benefit subadvisers, but the use of additional subadvisers could also result in increased costs to funds and their shareholders.
Commenters suggested that fund complexes that automate such calculations could incur significant one-time costs in connection with reconfiguring existing information collection systems to accommodate the amendments. The amendments will permit funds and companies they control to engage in otherwise prohibited transactions with: The Act's restrictions on transactions involving funds and their affiliated persons respond to market failures that can occur when an affiliated person, in a position to influence the management of a fund, causes the fund to behave in a manner that benefits the affiliated person, rather than the shareholders of the fund.
The amendments to rules 17a-6 and 17d-1 d 5 will permit market forces to operate to allocate resources in circumstances where market failure is unlikely because the affiliated person is not in a position to influence fund management. The amendments to rules 17a-6 and 17d-1 d 5 are unrelated to, and we believe will have no effect on, capital formation.
Subadvisory Affiliates New rule 17a and the amendments to rules 17e-1, 10f-3, and 12d permit funds, and companies controlled by funds, to engage in transactions with subadvisers that are affiliated persons of the fund, but which are not in a position to influence the fund's decision to participate in the transaction. The amendments to rule 17e-1 permit, in limited circumstances, an affiliated subadviser acting as broker to receive remuneration without complying with certain conditions of the rule.
As in the case of the amendments to rules 17a-6 and 17d-1 d 5 , we anticipate that these amendments will promote efficiency and competition by permitting market forces to operate in circumstances where there is limited chance of market failure.
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