The policy followed by AdvisorShares Investments, LLC (the “Advisor”) and the Trust for the disclosure of information about the portfolio holding of each series of the Trust (each a “Fund,” and collectively, the “Funds”) is described below. This Disclosure Policy is intended to ensure compliance by the Adviser and the Trust with (i) applicable regulations of the federal securities laws, including the Investment Company Act of 1940, as amended and the Investment Advisers Act of 1940 and (ii) general principles of fiduciary duty relating to client accounts. The Board of Trustees of the Trust must approve all material amendments to this policy.
The Funds are actively managed exchange-traded funds. Each business day, Fund portfolio holdings information will be provided to the Fund’s distributor or other agent for dissemination through the facilities of the NSCC and/or other fee-based subscription services to NSCC members and/or subscribers to those other fee-based subscription services, including authorized participants, and to entities that publish and/or analyze such information in connection with the process of purchasing or redeeming Creation Units or trading shares of the Fund in the secondary market. This information typically reflects the Fund’s anticipated holdings on the following business day. Daily access to information concerning the Fund’s portfolio holdings also is permitted (i) to certain personnel of those service providers that are involved in portfolio management and providing administrative, operational, risk management, or other support to portfolio management, including affiliated broker-dealers and/or Authorized Participants, and (ii) to other personnel of the Advisor, sub-advisor, if any, and other service providers, such as the Fund’s administrator, and Fund accountant, who deal directly with, or assist in, functions related to investment management, administration, custody and fund accounting, as may be necessary to conduct business in the ordinary course in a manner consistent with agreements with the Fund and/or the terms of the Fund’s current registration statement.
From time to time, information concerning Fund portfolio holdings, other than portfolio holdings information made available in connection with the creation/redemption process, as discussed above, may also be provided to other entities that provide additional services to the Fund, including, among others, rating or ranking organizations, in the ordinary course of business, no earlier than one business day following the date of the information. Portfolio holdings information made available in connection with the creation/redemption process may be provided to other entities that provide additional services to the Fund in the ordinary course of business after it has been disseminated to the NSCC.
The Fund’s Chief Compliance Officer, or a Compliance Manager designated by the Chief Compliance Officer, may also grant exceptions to permit additional disclosure of Fund portfolio holdings information at differing times and with different lag times (the period from the date of the information to the date the information is made available), if any, in instances where the Fund has legitimate business purposes for doing so, it is in the best interests of shareholders, and the recipients are subject to a duty of confidentiality, including a duty not to trade on the nonpublic information and are required to execute an agreement to that effect. The Board will be informed of any such disclosures at its next regularly scheduled meeting or as soon as is reasonably practicable thereafter. In no event shall the Fund, the Advisor, the sub-advisor, if any, or any other party receive any direct or indirect compensation in connection with the disclosure of information about the Fund’s portfolio holdings.