Statement Summary
On May 19, 2025, the SEC granted Connetic Venture Capital Access Fund and Connetic RIA, LLC exemptions under the Investment Company Act of 1940. This order allows registered closed-end management investment companies to:
- issue multiple classes of shares,
- impose early withdrawal charges, and
- implement asset-based distribution and service fees.
The application for these exemptions was filed on August 6, 2024, with amendments submitted in November 2024 and April 2025. A notice for public hearing was issued, but no requests were made. The SEC found that the exemptions align with public interest and investor protections, ensuring fair treatment among security holders. The order is effective immediately, adhering to specified conditions.
Original Statement
UNITED STATES OF AMERICA
BEFORE THE
SECURITIES AND EXCHANGE COMMISSION
INVESTMENT COMPANY ACT OF 1940
Release No. 35591 / May 19, 2025
In the Matter of
Connetic Venture Capital Access Fund
Connetic RIA, LLC
910 Madison Avenue
Covington, KY 41011
(812-15610)ORDER UNDER SECTION 6(c) OF THE INVESTMENT COMPANY ACT OF 1940
GRANTING AN EXEMPTION FROM SECTIONS 18(a)(2), 18(c) AND 18(i) OF THE ACT,
UNDER SECTIONS 6(c) AND 23(c) OF THE ACT GRANTING AN EXEMPTION FROM
RULE 23c-3 UNDER THE ACT AND PURSUANT TO SECTION 17(d) AND RULE 17d-1
UNDER THE ACT
Connetic Venture Capital Access Fund and Connetic RIA, LLC filed an application on August 6, 2024, and amendments on November 21, 2024, and April 17, 2025, requesting an order under section 6(c) of the Investment Company Act of 1940 (“Act”) granting an exemption from sections 18(a)(2), 18(c) and 18(i) of the Act; under sections 6(c) and 23(c) of the Act granting an exemption from rule 23c-3 under the Act; and pursuant to section 17(d) of the Act and rule 17d-1 under the Act. The order permits certain registered closed-end management investment companies to issue multiple classes of shares, impose early withdrawal charges, and impose asset-based distribution and/or service fees.
On April 21, 2025, a notice of the filing of the application was issued (Investment Company Act Release No. 35543). The notice gave interested persons an opportunity to request a hearing and stated that an order granting the application would be issued unless a hearing was ordered. No request for a hearing has been filed, and the Commission has not ordered a hearing.
The matter has been considered and it is found, on the basis of the information set forth in the application, as amended, that granting the requested exemption is appropriate in the public interest and consistent with the protection of investors and the purposes fairly intended by the policy and provisions of the Act.
It is further found that proposed repurchases will be made in a manner which does not unfairly discriminate against any holders of the class or classes of securities to be purchased.
It is further found that the investment company’s proposed institution of asset-based distribution and/or service fees is consistent with the provisions, policies, and purposes of the Act, and will not be on a basis different from or less advantageous than that of other participants.
Commission Orders
Accordingly, in the matter of Connetic Venture Capital Access Fund and Connetic RIA, LLC (File No. 812-15610), it is ordered:
- Under section 6(c) of the Act, that the requested exemption from sections 18(a)(2), 18(c), and 18(i) of the Act is granted, effective immediately, subject to the conditions contained in the application, as amended.
- Under sections 6(c) and 23(c) of the Act, that the requested exemption from rule 23c-3 under the Act is granted, effective immediately, subject to the conditions in the application, as amended.
- Pursuant to section 17(d) of the Act and rule 17d-1 under the Act, that the investment company’s institution of asset-based distribution and/or service fees is approved, effective immediately, subject to the conditions in the application, as amended.
For the Commission, by the Division of Investment Management, under delegated authority.
Sherry R. Haywood,
Assistant Secretary.
