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https://www.sec.gov/rules/ic/2014/ic-31300.pdf (footnotes omitted)The IIV is stale data. Unlike market maker proprietary algorithms, which rely on portfolio transparency and provide market makers with real-time data to effectively trade in today’s fast moving markets, IIV dissemination frequency is inadequate for purposes of making efficient markets in ETFs.27 Market makers operate at speeds calculated in fractions of a second.28 In today’s markets, 15 seconds is too long for purposes of efficient market making and could result in poor execution.29 Because an ETF is a derivative security, its current value changes every time the value of any underlying component of the ETF portfolio changes.30 Therefore, the IIV for a more frequently traded component security might not effectively take into account the full trading activity for that security, despite being available every 15 seconds.
For example, a large buy order for a component security held by the proposed ETF could temporarily spike the price of that security and, therefore, inflate the proposed ETF’s contemporaneous IIV calculation. 31 The IIV for the proposed ETF cannot adjust for such variations, whereas the NAV would.32 Therefore, relying on a stale IIV as a primary pricing signal for market making in Applicants’ proposed ETFs would not result in an effective arbitrage mechanism. 33
https://www.sec.gov/Archives/edgar/data/1499655/000114420419018151/tv518160_40-appa.htm[T]he custodian on behalf of the fund will share the end of day NAV portfolio (NAVP) with an independent valuation agent. Rather than publically disclosing portfolio composition, the valuation agent will calculate and disseminate a Verified Indicative Intraday Value (VIIV) at one-second intervals the following day based on the NAVP
https://www.sec.gov/Archives/edgar/data/1499655/000114420419018151/tv518160_40-appa.htmIn certain cases (e.g., some fixed income ETFs), the creation or redemption basket might contain different combinations of securities and/or cash relative to the overall ETF portfolio

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