SEC Issues Notice on RBB Fund Trust Exemption Application
The RBB Fund Trust and Millburn Ridgefield LLC seek SEC exemption to amend subadvisory agreements without shareholder vote, with a hearing deadline of Oct. 5, 2026.
The Securities and Exchange Commission released a notice on September 8, 2026 (Investment Company Act Release No. 36324; File No. 812-16043) concerning an application under section 6(c) of the Investment Company Act of 1940 for an exemption from Section 15(a) of the Act 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, if granted, would allow the RBB Fund Trust and Millburn Ridgefield LLC to enter into and materially amend subadvisory agreements with subadvisers without obtaining shareholder approval and would relieve the Applicants from the identified disclosure obligations related to fees paid to those subadvisers.
The application was originally filed on June 11, 2026 and amended on August 7, 2026. The Commission will issue an order granting the relief unless a hearing is requested. Requests for a hearing must be received by 5:30 p.m., Eastern time on October 5, 2026, and must include the file number, an affidavit or certificate of service, and a statement of the requester's interest and the issues contested.
Requests for hearing notifications may be sent to the SEC's Secretary via the email address listed in the notice. The Applicants are represented by Jillian L. Bosmann, Esq., of Faegre Drinker Biddle & Reath LLP, and Steven M. Felsenthal of Millburn Ridgefield LLC. For additional information, contact Trace W. Rakestraw, Senior Special Counsel, at (202) 551-6825.
The amended application dated August 7, 2026 is available through the SEC's website or the EDGAR system by searching the file number or the company names.
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