SEC Issues Notice of Manning & Napier Sub-Advisory Exemption Application
Manning & Napier Fund, its trust and advisor seek exemption from shareholder-approval and disclosure rules; hearing requests due Oct. 27, 2026
The Securities and Exchange Commission released a notice (FR Doc No. 2026-20502; Investment Company Act Release No. 36354; 812-16059) on October 2, 2026 regarding an application by Manning & Napier Fund, Inc., Manning & Napier Funds Trust, and Manning & Napier Advisors, LLC. The applicants request an exemption from section 15(a) of the Investment Company Act of 1940 and from specific disclosure requirements in rule 20a-1 (Item 19(a)(3) of Form N-1A), Items 22(c)(1)(ii), 22(c)(1)(iii), 22(c)(8) and 22(c)(9) of Schedule 14A, and sections 6-07(2)(a), (b) and (c) of Regulation S-X.
The exemption would permit the applicants to enter into and materially amend subadvisory agreements with subadvisers without obtaining shareholder approval and would relieve them of the disclosure obligations related to fees paid to those subadvisers.
The original application was filed on July 23, 2026 and was amended on August 21, 2026. Under the notice, an order granting the requested relief will be issued unless the Commission receives a hearing request. Interested parties must submit hearing requests by 5:30 p.m. Eastern Time on October 27, 2026, accompanied by proof of service on the applicants. Requests should be emailed to the SEC's Secretary and must reference the file number.
The applicants can be contacted at Paul J. Battaglia, c/o Manning & Napier Fund, Inc., 290 Woodcliff Drive, Fairport, NY 14450, with copies to counsel Sean Graber, Esq., and Timothy W. Levin, Esq. Further information, including the amended and restated application, is available through the SEC's EDGAR system or by contacting Senior Special Counsel Rachel Loko at (202) 6720.
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