ETF requirements (Rule 6c-11)

Five items posted prominently, with holdings due before the market opens each business day. The rule has no outage safe harbor.

ETFs relying on Rule 6c-11 must post five items "prominently" on the site, and the holdings file has a hard deadline: before regular trading opens on the listing exchange (9:30 a.m. ET for NYSE and Nasdaq listings). The failover origin must receive each day's data by the same deadline as the primary. Items below come from ADI 2025-15 unless noted.

Daily disclosures

ETF-01 Required

Daily holdings that form the basis of the next NAV, as of the prior business day close: ticker, CUSIP or other identifier, description, quantity, and percentage weight. SEC staff flagged sites missing CUSIPs.

Timing: Each business day, before market open
On failover: Dual publish (GEN-07); a daily check confirms today's as-of date by 9:00 a.m. ET
Basis: Rule 6c-11(c)(1)(i)

ETF-02 Required Counsel to confirm

Cash and foreign currency holdings are listed by specific currency (USD, EUR, JPY and so on), never rolled into a single "cash" line.

Timing: With ETF-01
On failover: Same feed as ETF-01

ETF-03 Required

NAV per share, market price, and premium or discount, each as of the prior business day close. Show premium/discount as a percentage of NAV, not dollars; staff flagged dollar figures. Use the terms "premium" and "discount."

Timing: Each business day
On failover: Same feed as ETF-01
Basis: Rule 6c-11(c)(1)(ii)

ETF-04 Required

30-day median bid-ask spread: rolling 30 calendar days, computed from the national best bid and offer. Label it "30-day median bid-ask spread"; staff flagged labels that dropped "30-day."

Timing: Each business day
On failover: Same feed as ETF-01
Basis: Rule 6c-11(c)(1)(v)

Premium and discount history

ETF-05 Required

Table showing the number of days at a premium and at a discount, for the most recently completed calendar year and each completed quarter of the current year (or the life of the fund if shorter).

Timing: Refresh within days of each quarter-end; staff found stale tables
On failover: Static HTML table, no database
Basis: Rule 6c-11(c)(1)(iii)–(iv)

ETF-06 Required

Line graph of daily premium/discount over the same period as ETF-05.

Timing: Same as ETF-05
On failover: Pre-rendered SVG or image, so it works with no JavaScript or third-party chart library
Basis: Rule 6c-11(c)(1)(iii)–(iv)

If an ETF's prospectus relies on website disclosure in place of premium/discount data in the prospectus and annual report (Form N-1A Items 11(g) and 27A(d)(4)), ETF-05 and ETF-06 are what make that prospectus accurate. One more reason they cannot lapse during an outage.

Conditional disclosures

ETF-07 Conditional

If the premium or discount exceeds 2% for more than 7 consecutive trading days: a statement saying so, plus a discussion of the factors reasonably believed to have caused it. Staff found many funds missed this.

Timing: Post immediately after the 8th trading day; keep for one year from first posting
On failover: Must sit on both origins for the full year; the evidence log (GEN-12) proves the posting date
Basis: Rule 6c-11(c)(1)(vi)

ETF-08 Recommended

An automated monitor counts consecutive trading days over 2% and alerts the client's compliance owner on day 6, so the statement is ready by day 8.

Timing: Daily
On failover: Runs off the shared feed, not either web origin

ETF-09 Conditional

Semi-transparent or non-transparent ETFs operating under an exemptive order: post the legend, tracking basket or other items their order requires, instead of or in addition to ETF-01.

Timing: Per the exemptive order
Basis: ADI 2025-15