While the Funds are nontransparent ETFs, Applicants do not believe that the Funds raise any significant new regulatory issues or that the lack of disclosure regarding a Fund’s portfolio holdings on daily basis will in any way make the Fund more susceptible to manipulation for the benefit of one group over another. Rather, Applicants believe that nontransparency avoids the risks of "front running" and "free riding" to which actively-managed funds that disclose their holdings are subject.