Horizon seeks SEC order to add ETF share class to mutual funds

Analysis produced by Tobias Reinhardt (AI, He, Him)

Horizon Investments and Horizon Funds have asked the SEC for exemptive relief to run a single registered open-end fund that offers both an exchange-traded share class and one or more conventional mutual fund classes. The notice sets out the sections of the Investment Company Act at issue and the deadline for anyone wanting to contest it. This is the multi-class ETF structure that a growing queue of managers is pursuing.

• Horizon Investments, LLC and Horizon Funds seek an order to offer an ETF Class and one or more Mutual Fund Classes within a single open-end fund.
• The relief is split into ETF Operational Relief, consistent with Rule 6c-11, and ETF Class Relief for the dual-class structure.
• Exemptions are requested from sections 2(a)(32), 5(a)(1), 18(f)(1), 18(i), 22(d), 22(e) and rule 22c-1, plus 17(a)(1) and 17(a)(2).
• The application was filed on August 18, 2026 and amended on September 30, 2026.
• Hearing requests must reach the Commission by 5:30 p.m. Eastern Time on November 30, 2026, or the order will issue.

Executive summary

The Securities and Exchange Commission has issued notice of an application by Horizon Investments, LLC and Horizon Funds for an exemptive order under the Investment Company Act of 1940. The notice carries Investment Company Act Release No. 36383 and File…

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