WASHINGTON — The U.S. Securities and Exchange Commission (SEC) has announced its intention to approve a novel exemptive application to permit Dimensional Fund Advisors to offer investment companies with mutual fund share classes and exchange-traded fund (ETF) share classes. Stradley Ronon serves as counsel to the Dimensional funds and prepared the exemptive application. The SEC issued its notice on September 29 after Dimensional filed its third amended application on September 26 for relief from certain provisions of the Investment Company Act of 1940 to operate such funds. “This relief could be a watershed moment by permitting asset managers to utilize the ETF class structure to deliver potential benefits of economies of scale and tax efficiency to fund shareholders and promote greater investor choice,” said partner Michael Mundt, part of the Stradley Ronon team who assisted with the application. “Stradley Ronon is pleased to have helped Dimensional and its funds achieve this regulatory breakthrough.” Dimensional currently advises mutual funds and is also one of the largest active ETF sponsors ranked by assets under management. The exemptive application is the longest pending application of more than 80 applications filed by fund sponsors to obtain this relief. The Dimensional application has served as the model for the other filings, and the fund industry has been closely monitoring SEC action on the Dimensional request. Following the SEC’s public notice of the application, if no requests are made for a hearing, the SEC is expected to issue an order granting exemptive relief. If granted, the relief will allow Dimensional to offer ETFs as a share class within a multiple share class structure (ETF share class). The Stradley Ronon team representing the Dimensional funds in this matter also includes partners Bruce Leto and Jana Cresswell. Since 1982, Stradley Ronon has assisted the Dimensional funds on a variety of novel innovations and industry-firsts, including working with Dimensional on the first major conversion of mutual funds to ETFs at scale. In addition, Stradley Ronon recently updated the firm’s digital report, “Making Sense of ETF Share Class Applications,” analyzing the pending ETF share class applications, with the latest update providing new insights into the ETF share class governance framework, highlighting its impact on boards and advisers, and outlining how product development teams should be preparing for the regulatory development. For more information: https://www.sec.gov/files/rules/ic/2025/ic-35770.pdf About Stradley Ronon’s ETF Practice: Stradley Ronon’s ETF practice provides representation to the independent directors, advisers and/or ETFs for three of the four largest ETF groups. Our ETF practitioners have been at the forefront of recent ETF regulatory developments and novel product innovation, including applications for ETF share class relief; SEC approvals of ETFs that use less transparent, active management strategies; and mutual-fund-to-ETF conversions. Stradley Ronon also collaborated with the Independent Directors Council to publish an update to its white paper on board oversight of ETFs. About Stradley Ronon Stevens & Young, LLP Counseling clients since 1926, Stradley Ronon has helped private and public companies — from small businesses to Fortune 500 corporations — achieve their goals by providing pragmatic, value-driven legal counsel. With offices coast to coast, our lawyers seamlessly address the full spectrum of our clients’ needs, ranging from sophisticated corporate transactions to complex commercial litigation.