Tag Archives: brendan-ahern

The Facts On China’s June Correction

Summary China’s onshore markets experienced a pullback in June. The underlying factors that caused the onshore markets to rise are still intact. The government has met the pullback with a powerful intervention. July 16, 2015 – A strong stock market benefits China’s key policy goals: Renminbi, RMB, internationalization, increased domestic consumption, and unlocking shareholder value in state owned enterprises. The markets’ more prominent role in helping China achieve these goals is one explanation for the rise in the onshore markets, which are up 110% over the past year1. Due to this increased emphasis, China met the recent pullback with a powerful intervention. The cause of the pullback and the Chinese government’s actions to contain it can be confusing to investors outside of China. In this piece we provide an up to date overview of the onshore markets and outline why we believe China is still an attractive investment opportunity. Recent Events Stock investing in China is still a new concept and the majority of Chinese households have less money in the markets than those in the United States. Market exposure on a household basis has yet to be institutionalized in China like it is in the U.S., for instance there are no 401k plans in onshore China, thus the market’s drop adversely effects a smaller subset of the population in China than it would in the United States. In the U.S. the savings rate is 5.1%2 with 25% of net worth going into the markets3. In China the savings rate is an impressive 50%4, however, according to China economic research firm PRC Macro, the average household only has 4.4% of their net worth5 invested in the stock market. Based on this comparison, China’s household participation in the stock market compared to its savings rate is relatively low. China’s leadership understands this disparity and has encouraged its people to invest in the capital markets to bring their participation rates up to par with developed nations and to institutionalize the market. This trend is apt to continue in the years to come, which could act as tailwind for investors. Reasons for the June pullback With such a massive influx of investors into the markets as China is currently experiencing, there is bound to be some measure of volatility. The adoption of margin by investors with little stock market experience struck us as imprudent. We believe overextension of margin was the primary cause of the June pullback. Individual retail investors, who represent 85%7 of the market in onshore China, invested heavily in small cap stocks. These individuals bought on margin, leveraging their capital to cover the costs. Before the decrease in Chinese stock prices in June, brokerage margin increased as the onshore market performed well over the last year. In addition, as the markets continued to grow, the use of over the counter, OTC, margin increased. OTC margin is money leant by non-brokerage firms outside of the regulated markets and, in the case of China, allowed leverage upwards of three to five times the money deposited. While it is difficult to gauge exactly how much OTC margin was in the markets at their peak, between the months of March and May of 2015, it is estimated to have been between 1.5 and 2 trillion RMB8. When a large number of Initial Public Offerings,IPOs, and secondary offerings took place in June, Chinese investors started selling their small cap shares in order to invest in the IPOs. As a result, supply overwhelmed demand and triggered a cascade of selling that led to a significant amount of margin calls. A margin call occurs when a broker asks for more capital from an investor to cover a decrease in value of a stock. Halted and Suspended Securities In order to prevent large numbers of investors from being forced to sell due to compounding margin calls, regulators took the unprecedented measure of allowing companies, particularly small cap companies, to voluntarily halt trading in their stocks. The regulators realized that OTC margin, which is outside the scope of their regulatory purview, had the potential to be a systematic threat to the stock market. While stocks halted, regulators could deleverage both brokerage and OTC margin accounts. OTC margin has fallen 66% in the last several weeks alone due to this effort.9 Our partners in onshore China have reported that the OTC margin business has been largely shut down. While many press reports highlighted the number of stocks halted they failed to show the size of these companies. According to Bloomberg, As of July 15’s close in China the number was 10. 75% (2,211 stocks) are trading, which is 88% of the 6.5 trillion total market cap for the 2951 stocks listed in the onshore exchanges. 4% (132) are suspended, representing 4% of market cap. 18% (540) are halted, representing 8% of the market cap 2% (68) are inactive, representing 0% of the market cap; these companies were scheduled to have initial public offerings but had their IPOs suspended due to a moratorium on new IPOs. Our portfolios hold predominantly large cap stocks and some mid-cap stocks. Media reports on halted stocks were correct in the number of stocks halted, however, they failed to note the majority of these halts were small or micro cap stocks. Valuations We previously stated that we believe investors should avoid small cap stocks due to high valuations. Even today the ChiNext stocks, a segment of the Shenzhen Stock Exchange that represents small cap growth companies, are two standard deviations11 above their average price-to-equity,P/E12 of 55 at 86, though down from their June 3 high of 14713. The MSCI China A International Index currently have a forward P/E of 15 while the combined Shanghai and Shenzhen Composite has a P/E of 17 versus its ten-year average of 1915. Where do we go from here? While not of the same magnitude as 2008, there are parallels between China’s recent correction and the U.S. housing crisis. In both cases, standards amongst lenders varied and in many cases decreased over time. Just as no document home mortgages in the U.S. were allowed despite rational thinking, retail investors in onshore China were able to obtain questionable amounts of leverage. Ultimately the U.S. housing market fell and regulators instituted new standards. In China regulators are instituting new policies prohibiting OTC margin. We hope means based testing for the use of margin at brokerage houses is also instituted. Much like how the U.S. housing crisis and subsequent recovery affected certain geographic areas more than other areas, China’s stock market is not apt to see a uniform rise. We believe investors should continue to underweight small cap securities due to high valuations and instead favor large cap stocks, which have returned to their historical average valuations15. We believe China will continue to pursue policies that aid its ascent as a global economic power. China is focused on increasing global competitiveness of State Owned Enterprises, we believe these stocks have potential to continue to perform well. Between China’s continued development policies and MSCI’s forthcoming inclusion of onshore equities, we believe investors should seek greater exposure to onshore China. As China evolves from being a retail market dominated by individual investors to an institutional oriented market like that of the United States we believe its markets may continue to grow and perform well. 1 Data based on MSCI China A International Index as of 7/14/15. 2 Data from World Bank as of 2013. Savings rate: The amount of money, expressed as a percentage or ratio, that one deducts from his/her disposable personal income to set aside as a nest egg or for retirement. 3 U.S. Federal Reserve. “Financial Accounts of the United States: Flow of Funds, Balance Sheets, and Integrated Macroeconomic Accounts” June 11, 2015. 4 Data from World Bank as of 2013. 5 Data from PRC Macro as of 4/28/2015. 6 Margin: The purchase of an asset by paying the margin and borrowing the balance from a bank or broker. Buying on margin refers to the initial or down payment made to the broker for the asset being purchased. The collateral for the funds being borrowed is the marginable securities in the investor’s account. Before buying on margin, an investor needs to open a margin account with the broker. 7 Data from the Shanghai Stock Exchange as of 2012 8 Ai Jingwei. “OTC how to raise capital with the stock market”, Sina Finance, 7/14/2015. 9 Percent change calculated from data reported by Sina Finance (source 7) and People’s Daily, “From The CSRC: The Amount of Off-Balance Sheet Lending is Close to 500 Billion, 15 Billion Forced to Close Shop”, People’s Daily, 6/30/2015. Previous amount of margin was approximately 1.5 trillion RMB between March to May 2015 according to Sina Finance. The current amount of margin is now 0.5 trillion RMB as of 6/30/2015 according to People’s Daily. 10 Data from Bloomberg as of 7/15/2015. 11 Standard Deviation: A measure of the dispersion of a set of data from its mean. The more spread apart the data, the higher the deviation. Standard deviation is calculated as the square root of variance. 12 Price-to-equity: A ratio used to compare a stock’s market value to its book value. It is calculated by dividing the current closing price of the stock by the latest quarter’s book value per share. 13 Data from Bloomberg as of 7/14/2015. 14 Data from Bloomberg as of 7/14/2015. 15 Data from Bloomberg as of 7/14/2015. Disclosure: I am/we are long KBA, KEMP, KWEB, KFYP. (More…) I wrote this article myself, and it expresses my own opinions. I am not receiving compensation for it (other than from Seeking Alpha). I have no business relationship with any company whose stock is mentioned in this article. Additional disclosure: ©2015 KraneShares Carefully consider the Funds’ investment objectives, risk factors, charges and expenses before investing. This and additional information can be found in the Funds’ prospectus, which may be obtained here: KBA, KFYP, KWEB, KCNY, KEMP Read the prospectus carefully before investing. Investing involves risk, including possible loss of principal. There can be no assurance that a Fund will achieve its stated objectives. The Funds focus their investments primarily with Chinese issuers and issuers with economic ties to China. The Funds are subject to political, social or economic instability within China which may cause decline in value. Fluctuations in currency of foreign countries may have an adverse effect to domestic currency values. Emerging markets involve heightened risk related to the same factors as well as increase volatility and lower trading volume. Current and future holdings are subject to risk. Narrowly focused investments and investments in smaller companies typically exhibit higher volatility. Internet companies are subject to rapid changes in technology, worldwide competition, rapid obsolescence of products and services, loss of patent protections, evolving industry standards and frequent new product productions. Such changes may have an adverse impact on performance. The ability of the KraneShares Bosera MSCI China A ETF to achieve its investment objective is dependent on the continuous availability of A Shares and the ability to obtain, if necessary, additional A Shares quota. If the Fund is unable to obtain sufficient exposure due to the limited availability of A Share quota, the Fund could seek exposure to the component securities of the Underlying Index by investing in depositary receipts. The Fund may, in some cases, also invest in Hong Kong listed versions of the component securities and B Shares issued by the same companies that issue A Shares in the Underlying Index. The Fund may also use derivatives or invest in ETFs that provide comparable exposures. The ability of the KraneShares FTSE Emerging Markets Plus ETF to achieve its investment objective is dependent, in part, on the continuous availability of A Shares through the Fund’s investment in the KraneShares Bosera MSCI China A Share ETF and that fund’s continued access to the China A Shares market. If such access is lost or becomes inadequate to meet its investment needs, it may have a material adverse effect on the ability of the Fund to achieve its investment objective because shares of the KraneShares Bosera MSCI China A Share ETF may no longer be available for investment by the Fund, may trade at a premium to NAV, or may no longer be a suitable investment for the Fund. The KraneShares FTSE Emerging Markets Plus ETF and KraneShares Bosera MSCI China A Share ETF may be concentrated in the financial services sector. Those companies may be adversely impacted by many factors, including, government regulations, economic conditions, credit rating downgrades, changes in interest rates, and decreased liquidity in credit markets. This sector has experienced significant losses in the recent past, and the impact of more stringent capital requirements and of recent or future regulation on any individual financial company or on the sector as a whole cannot be predicted. These ETFs may also invest in derivatives. Investments in derivatives, including swap contracts and index futures in particular, may pose risks in addition to those associated with investing directly in securities or other investments, including illiquidity of the derivatives, imperfect correlations with underlying investments, lack of availability and counterparty risk. The use of swap agreements entails certain risks, which may be different from, and possibly greater than, the risks associated with investing directly in the underlying asset. The KraneShares E Fund China Commercial Paper ETF is subject to interest rate risk, which is the chance that bonds will decline in value as interest rates rise. It is also subject to income risk, call risk, credit risk, and Chinese credit rating risks. The components of the securities held by the Fund will be rated by Chinese credit rating agencies, which may use different criteria and methodology than U.S. entities or international credit rating agencies. The Fund may invest in high yield and unrated securities, whose prices are generally more sensitive to adverse economic changes. As such, their prices may be more volatile. The Fund is subject to industry concentration risk and is nondiversified. The KraneShares E Fund China Commercial paper ETF invests in sovereign and quasi-sovereign debt. Investments in sovereign and quasi-sovereign debt securities involve special risks, including the availability of sufficient foreign exchange on the date a payment is due, the relative size of the debt service burden to the economy as a whole, and the government debtor’s policy towards the International Monetary Fund and the political constraints to which a government debtor may be subject. In order to qualify for the favorable tax treatment generally available to regulated investment companies, the Fund must satisfy certain income and asset diversification requirements each year. If the Fund were to fail to qualify as a regulated investment company, it would be taxed in the same manner as an ordinary corporation, and distributions to its shareholders would not be deductible by the Fund in computing its taxable income. Narrowly focused investments typically exhibit higher volatility. Internet companies are subject to rapid changes in technology, worldwide competition, rapid obsolescence of products and services, loss of patent protections, evolving industry standards and frequent new product productions. Such changes may have an adverse impact on performance. The KraneShares ETFs are distributed by SEI Investments Distribution Company, 1 Freedom Valley Drive, Oaks, PA 19456, which is not affiliated with Krane Funds Advisors, LLC, the Investment Adviser for the Fund.

Not If, But When – A Breakdown Of MSCI’s Decision On China’s Onshore Equity Market

Summary On June 9th, MSCI stated that onshore Chinese equities will be added to their broad-based international indices. We believe investors should consider taking a position in the onshore markets today as international investment increases and China implements policies to sustain the onshore market rally. Three issues need to be resolved before immediate inclusion can take place. MSCI, a leading provider of index solutions globally, announced on Tuesday, June 9th that onshore Chinese equities will be added to their broad-based international indices upon the resolution of three outstanding issues. We previously wrote about the potential impact of this inclusion. As an MSCI client, KraneShares, along with several dozen mutual fund families and institutional brokers, attended MSCI’s Index Review Seminar, which was held the morning after the announcement. MSCI’s message at the seminar was clear; investors need to proactively prepare for the coming changes. Changes like the one MSCI announced on June 9th are rare, but when they happen they have historically driven performance in the affected economies. For example, in 2012 MSCI announced that it would include the United Arab Emirates in its emerging market index between 2012 and 2014; when the UAE’s inclusion was implemented, the MSCI United Arab Emirates IMI Index rose 238%1. This dwarfs the 130% rise the onshore Chinese markets have achieved since the rally began in the second quarter of 20142. We believe the onshore markets still have room to grow. Beyond MSCI’s decision, the recent surge in China’s onshore markets is backed by meticulous structural developments that have been decades in the making. We have listed a few examples of these developments below: Raising Domestic Consumption China’s policy makers are prioritizing increased domestic consumption in order to alleviate export dependency to the European Union and United States. Evidence of the policy’s success can be seen in China’s Year over Year retail sales data. According to China’s National Bureau of Statistics, retail sales in May increased 10.1% to $390 billion. The numbers indicate that China is catching up to well-established domestic markets like the United States. Additionally, the strong stock market has a trickle-down wealth effect on domestic consumption allowing Chinese investors to spend more freely. Stock Investing Replaces Housing China’s household savings rate is the third highest in the world at 51% of its GDP3. This rate is 300% higher than that of the United States4. Due to limited investment options in China, housing has traditionally been one of the most popular investment vehicles for Mainland Chinese citizens, which in return supported China’s urbanization policy. With housing softening, savings are finding a new home in the stock market. In fact, 4.4 million new onshore brokerage accounts have been opened by Chinese investors this year5. Monetary Policy China’s central bank has started to ease monetary policy. There have been two interest rate cuts and several adjustments to the reserve requirement ratio, which is the minimum amount of customer deposits that commercial banks must hold in reserve before making loans. The reserve requirement ratio was cut to 19.5% this year from 20% in 20146. More bank requirement cuts and targeted monetary policy are likely as policy makers continue to support growth. However, we do not believe that there will be more interest rate cuts because China’s leadership wants to keep the renminbi, RMB, stable ahead of the International Monetary Fund’s decision on the RMB’s inclusion into its basket of reserve currencies. Unlocking Shareholder Value in State Owned Enterprise Historically, China’s State Owned Enterprises, SOEs, have been undervalued compared to their privately owned counterparts. Unlocking shareholder value in state owned enterprises is a top policy in China today. This will take the form of increased mergers and acquisitions like the recent merger of China South Railroad with China North Railroad to form CRRC, one of the largest train manufacturers globally. Removing inefficiencies should raise the return on equity for State Owned Enterprises versus their private equivalents. We envision reform to heavily emphasize traditional sectors including industrials, basic materials and energy. One Belt, One Road Recently, China implemented the One Belt, One Road policy, which links Chinese manufacturers to Europe, Asia, Africa and the Middle East through improved overland transportation linkages and maritime port and logistic facilities. This spearheaded the launch of the Asia Infrastructure Investment Bank, AIIB, to help finance this policy. Debt Deleveraging China heavily restricted Initial Public Offerings and secondary offerings in the onshore markets for several years. Chinese companies had to rely on issuing debt to raise capital due to this limiting environment. The strong performance of the stock market allows new companies to list and for legacy companies to issue new shares. Proceeds can be used to pay down debt. The MSCI decision overview As the inclusion of the onshore market into MSCI broad indices has become a matter of when not if, China’s leadership is preparing its economy for massive inflows of foreign capital. Currently, China’s Securities Regulatory Commission, CSRC, is working with MSCI to address the three pending issues. The issues center around the programs China implemented in order to phase in the opening up of its economy. China has tightly regulated quota systems to allow foreign investors access to its onshore markets. The first program China launched was the Qualified Foreign Institutional Investor program, QFII, which gives specific foreign institutions access to the onshore markets. The second program to launch was the Renminbi Qualified Foreign Institutional Investor Program, RQFII, which is issued primarily to Chinese asset managers, and has been the catalyst for the launch of onshore China funds. China is gradually shifting focus from the QFII and RQFII programs in favor of even more accessible “connect” programs. The first connect program to go live was the Shanghai-Hong Kong Stock Connect that linked the Shanghai Stock Exchange to the fully internationally accessible Hong Kong Stock Exchange. We believe the Shenzhen-Hong Kong Stock Connect program should follow soon, which will make the entire onshore market fully accessible to international investors. The three issues: Quota Allocation Process: In its announcement MSCI stated that QFII and RQFII quota is still an issue because: “Large investors should be given access to quota commensurate with the size of their assets.”7 We believe this issue will be settled in the near future because quota restrictions are consistently being loosened. Capital Mobility Restrictions: The Shanghai-Hong Kong Stock Connect has a daily limit on the amount of stocks that can be purchased, which, if reached, could leave managers without access. MSCI would like to see this limit removed. Additionally the QFII program has a weekly redemption window, which MSCI would like to see increased to a daily window. Beneficial Ownership: Unlike ETFs and mutual funds, investors in separate managed accounts own the actual underlying securities held by their custodian. MSCI wants to ensure that investors with separate accounts are confident in their ownership in Chinese stock. Before the June 9th announcement there were lingering questions around how the onshore markets would be phased in. MSCI clarified that initially 5% of the onshore Chinese equities’ free float market cap would be included into their broad indices and that this weight will be increased incrementally. At full inclusion, China’s weight within MSCI Emerging Markets would be 43.6% overall, 20.3% Hong Kong listed companies, 20.5% onshore Chinese companies, and 2.8% U.S.-listed companies7. An incremental increase of onshore equities within broader indices is a logical strategy based on the large amount of money needing to be reallocated. We previously wrote about how the lack of a formal announcement on the Shenzhen-Hong Kong Stock Connect program could be problematic for inclusion. We suspect an official announcement about the launch of this program in the next several months. Ultimately the impediments are coming down as MSCI calls the launch of the Shenzhen-Connect program “imminent” and believes “further liberalization of the RQFII program”7 is coming. China’s leadership is motivated to continue opening up its economy to international investors. Having China’s onshore markets included into international indices helps bolster this goal. We believe investors should consider taking a position in the onshore China markets today as their inclusion within broad MSCI indices – and the accompanying international fund flows – are imminent and China is enacting policies to sustain the onshore market rally. 1 Return based off the MSCI United Arab Emirates IMI Index from January 2012 to May 2014. Definition: The MSCI United Arab Emirates Investable Market Index is designed to measure the performance of the large, mid, and small cap segments of the UAE markets. With 22 constituents, the index covers approximately 85% of the UAE equity universe. 2 Return based of the MSCI China A International Index from start of market rally 3/1/2014 through 5/31/2015. MSCI China A International Index Definition: The MSCI China A International Index captures large and mid-cap representation and includes the China A-share constituents of the MSCI China All Shares Index. It is based on the concept of the integrated MSCI China equity universe with China A-shares included. 3 Source: World Bank as of 2013 4 Source: World Bank as of 2013 5 Source: China Securities Depository and Clearing Corporation as of 5/2015 6 Source: CEIC Data as of 2/5/2015 7 Source for quote – MSCI, “Results of MSCI 2015 Market Classification Review” 6/9/2015 8 MSCI as of 6/2015 Disclosure: I am/we are long KBA, KEMP, KCNY, KFYP, KWEB. (More…) I wrote this article myself, and it expresses my own opinions. I am not receiving compensation for it (other than from Seeking Alpha). I have no business relationship with any company whose stock is mentioned in this article. Additional disclosure: ©2015 KraneShares Carefully consider the Funds’ investment objectives, risk factors, charges and expenses before investing. This and additional information can be found in the Funds’ prospectus, which may be obtained here: KBA, KFYP, KWEB, KCNY, KEMP Read the prospectus carefully before investing. Investing involves risk, including possible loss of principal. There can be no assurance that a Fund will achieve its stated objectives. The Funds focus their investments primarily with Chinese issuers and issuers with economic ties to China. The Funds are subject to political, social or economic instability within China which may cause decline in value. Fluctuations in currency of foreign countries may have an adverse effect to domestic currency values. Emerging markets involve heightened risk related to the same factors as well as increase volatility and lower trading volume. Current and future holdings are subject to risk. Narrowly focused investments and investments in smaller companies typically exhibit higher volatility. Internet companies are subject to rapid changes in technology, worldwide competition, rapid obsolescence of products and services, loss of patent protections, evolving industry standards and frequent new product productions. Such changes may have an adverse impact on performance. The ability of the KraneShares Bosera MSCI China A ETF to achieve its investment objective is dependent on the continuous availability of A Shares and the ability to obtain, if necessary, additional A Shares quota. If the Fund is unable to obtain sufficient exposure due to the limited availability of A Share quota, the Fund could seek exposure to the component securities of the Underlying Index by investing in depositary receipts. The Fund may, in some cases, also invest in Hong Kong listed versions of the component securities and B Shares issued by the same companies that issue A Shares in the Underlying Index. The Fund may also use derivatives or invest in ETFs that provide comparable exposures. The ability of the KraneShares FTSE Emerging Markets Plus ETF to achieve its investment objective is dependent, in part, on the continuous availability of A Shares through the Fund’s investment in the KraneShares Bosera MSCI China A Share ETF and that fund’s continued access to the China A Shares market. If such access is lost or becomes inadequate to meet its investment needs, it may have a material adverse effect on the ability of the Fund to achieve its investment objective because shares of the KraneShares Bosera MSCI China A Share ETF may no longer be available for investment by the Fund, may trade at a premium to NAV, or may no longer be a suitable investment for the Fund. The KraneShares FTSE Emerging Markets Plus ETF and KraneShares Bosera MSCI China A Share ETF may be concentrated in the financial services sector. Those companies may be adversely impacted by many factors, including, government regulations, economic conditions, credit rating downgrades, changes in interest rates, and decreased liquidity in credit markets. This sector has experienced significant losses in the recent past, and the impact of more stringent capital requirements and of recent or future regulation on any individual financial company or on the sector as a whole cannot be predicted. These ETFs may also invest in derivatives. Investments in derivatives, including swap contracts and index futures in particular, may pose risks in addition to those associated with investing directly in securities or other investments, including illiquidity of the derivatives, imperfect correlations with underlying investments, lack of availability and counterparty risk. The use of swap agreements entails certain risks, which may be different from, and possibly greater than, the risks associated with investing directly in the underlying asset. The KraneShares E Fund China Commercial Paper ETF is subject to interest rate risk, which is the chance that bonds will decline in value as interest rates rise. It is also subject to income risk, call risk, credit risk, and Chinese credit rating risks. The components of the securities held by the Fund will be rated by Chinese credit rating agencies, which may use different criteria and methodology than U.S. entities or international credit rating agencies. The Fund may invest in high yield and unrated securities, whose prices are generally more sensitive to adverse economic changes. As such, their prices may be more volatile. The Fund is subject to industry concentration risk and is nondiversified. The KraneShares E Fund China Commercial paper ETF invests in sovereign and quasi-sovereign debt. Investments in sovereign and quasi-sovereign debt securities involve special risks, including the availability of sufficient foreign exchange on the date a payment is due, the relative size of the debt service burden to the economy as a whole, and the government debtor’s policy towards the International Monetary Fund and the political constraints to which a government debtor may be subject. In order to qualify for the favorable tax treatment generally available to regulated investment companies, the Fund must satisfy certain income and asset diversification requirements each year. If the Fund were to fail to qualify as a regulated investment company, it would be taxed in the same manner as an ordinary corporation, and distributions to its shareholders would not be deductible by the Fund in computing its taxable income. Narrowly focused investments typically exhibit higher volatility. Internet companies are subject to rapid changes in technology, worldwide competition, rapid obsolescence of products and services, loss of patent protections, evolving industry standards and frequent new product productions. Such changes may have an adverse impact on performance. The KraneShares ETFs are distributed by SEI Investments Distribution Company, 1 Freedom Valley Drive, Oaks, PA 19456, which is not affiliated with Krane Funds Advisors, LLC, the Investment Adviser for the Fund.