Treasury
3-MO 3.83% +1bp 6-MO 3.98% unch 1-YR 4.08% +4bp 2-YR 4.28% +5bp 3-YR 4.34% +4bp 5-YR 4.45% +7bp 7-YR 4.59% +7bp 10-YR 4.75% +7bp 20-YR 5.28% +6bp 30-YR 5.27% +6bp 3-MO 3.83% +1bp 6-MO 3.98% unch 1-YR 4.08% +4bp 2-YR 4.28% +5bp 3-YR 4.34% +4bp 5-YR 4.45% +7bp 7-YR 4.59% +7bp 10-YR 4.75% +7bp 20-YR 5.28% +6bp 30-YR 5.27% +6bp 3-MO 3.83% +1bp 6-MO 3.98% unch 1-YR 4.08% +4bp 2-YR 4.28% +5bp 3-YR 4.34% +4bp 5-YR 4.45% +7bp 7-YR 4.59% +7bp 10-YR 4.75% +7bp 20-YR 5.28% +6bp 30-YR 5.27% +6bp 3-MO 3.83% +1bp 6-MO 3.98% unch 1-YR 4.08% +4bp 2-YR 4.28% +5bp 3-YR 4.34% +4bp 5-YR 4.45% +7bp 7-YR 4.59% +7bp 10-YR 4.75% +7bp 20-YR 5.28% +6bp 30-YR 5.27% +6bp 3-MO 3.83% +1bp 6-MO 3.98% unch 1-YR 4.08% +4bp 2-YR 4.28% +5bp 3-YR 4.34% +4bp 5-YR 4.45% +7bp 7-YR 4.59% +7bp 10-YR 4.75% +7bp 20-YR 5.28% +6bp 30-YR 5.27% +6bp 3-MO 3.83% +1bp 6-MO 3.98% unch 1-YR 4.08% +4bp 2-YR 4.28% +5bp 3-YR 4.34% +4bp 5-YR 4.45% +7bp 7-YR 4.59% +7bp 10-YR 4.75% +7bp 20-YR 5.28% +6bp 30-YR 5.27% +6bp
US Treasury par yield curve · Jul 31 · Source: U.S. Treasury
Saturday, August 1, 2026
U.S. Edition
File 812-16049

Baillie Gifford has asked the SEC to let one fund sell both mutual fund shares and ETF shares, and the order issues automatically unless somebody objects by 24 August

A close photograph of a warm brown matte surface filling the entire frame, its fine granular texture raised into thousands of small even peaks that catch a soft light falling from the upper left. No text, markings, brand marks, people or objects are in view. A generic material close-up, not a photograph of any fund, filing, exchange or office.
Photo: Turgay Koca / Pexels

The order has not been granted yet, and it does not need anybody to grant it.

That is the operative sentence in a notice the Securities and Exchange Commission filed for public inspection on Friday: an order granting the requested relief will be issued unless the Commission orders a hearing. Hearing requests are due by 5:30 p.m. Eastern on 24 August. Absent one, the application clears.

What Baillie Gifford Funds, Baillie Gifford ETF Trust and Baillie Gifford Overseas Limited applied for on 2 July is permission to run a single registered open-end fund carrying two very different kinds of share at once. One class would trade on an exchange and operate as an ETF. One or more other classes would not trade at all, and would work as ordinary mutual fund shares. The notice calls the result a Multi-Class ETF Fund.

The two pieces of relief

The application asks for the relief in two named parts, and the split is informative.

The first is what the notice calls ETF Operational Relief, being what any fund needs to run standard exchange-traded operations consistent with Rule 6c-11. The second is ETF Class Relief, being what a fund additionally needs in order to hang that exchange-traded class off a fund that also has non-traded classes. The second part is the unusual one.

The sections being set aside

The list of statutory provisions tells you where the friction is.

The application seeks exemptions from sections 2(a)(32), 5(a)(1), 18(f)(1), 18(i), 22(d) and 22(e) of the Investment Company Act, from rule 22c-1, and, under sections 6(c) and 17(b), from sections 17(a)(1) and 17(a)(2). Those cover capital structure, equal voting rights across shares, the requirement to sell at a price based on current net asset value, and transactions with affiliated persons. Each is a rule that a conventional mutual fund satisfies without effort and an exchange-traded class does not.

What the notice does not say

It names no fund and no fee. It gives no launch date and no asset figure.

It also does not carry the conditions that will attach to any order, which is the part that will matter most. For those, and for the applicants' representations and legal analysis, the notice points to the application itself, filed on 2 July and available on EDGAR under the same file number.

The document: Securities and Exchange Commission, Investment Company Act Release No. 36275, file number 812-16049, notice dated 29 July 2026, captioned Baillie Giffords Funds, et al. FR Doc. 2026-15604, filed for public inspection at 08:45 on 31 July 2026, publication date 3 August 2026, issued for the Commission by the Division of Investment Management under delegated authority and signed by Sherry R. Haywood, Assistant Secretary. The raw text of the notice was fetched from federalregister.gov and read in full here; no fetch-tool summary was relied on, and every date, name, statutory section and rule citation below was matched against that text. Verified: the notice is a notice of an application under section 6(c) of the Investment Company Act of 1940 for an exemption from sections 2(a)(32), 5(a)(1), 18(f)(1), 18(i), 22(d) and 22(e) of the Act and rule 22c-1 under the Act, and under sections 6(c) and 17(b) of the Act for an exemption from sections 17(a)(1) and 17(a)(2) of the Act. Verified on what is sought, in the notice's own terms: applicants request an order that would permit a registered open-end management investment company to offer one class of exchange-traded shares that operates as an exchange-traded fund, defined in the notice as an ETF Class with such shares being ETF Shares, and one or more classes of shares that are not exchange-traded, each such class defined as a Mutual Fund Class with such shares being Mutual Fund Shares, and each such fund defined as a Multi-Class ETF Fund; and the order would provide Multi-Class ETF Funds with two broad categories of relief, being the relief necessary to permit standard exchange-traded fund operations consistent with Rule 6c-11 under the Act, defined as ETF Operational Relief, and the relief necessary for a fund to offer an ETF Class and one or more Mutual Fund Classes, defined as ETF Class Relief. Verified on parties and dates: the applicants are Baillie Gifford Funds, Baillie Gifford ETF Trust, and Baillie Gifford Overseas Limited; the application was filed on 2 July 2026; and hearing requests should be received by the Commission by 5:30 p.m. Eastern time on 24 August 2026, accompanied by proof of service on the applicants. Verified on the disposition mechanism, quoted from the notice: an order granting the requested relief will be issued unless the Commission orders a hearing. Verified on procedure: interested persons may request a hearing by emailing the Commission's Secretary at Secretarys-Office@sec.gov and serving the applicants with a copy; under rule 0-5 hearing requests should state the nature of the writer's interest, any facts bearing upon the desirability of a hearing, the reason for the request, and the issues contested; and persons who wish to be notified of a hearing may request notification from the same address. Verified on addresses and contacts: the applicant addresses given are Gareth Griffiths, Calton Square, 1 Greenside Row, Edinburgh, Scotland, United Kingdom EH1 3AN, and George Raine, Esq., Ropes & Gray LLP, 800 Boylston Street, Boston, Massachusetts 02199; the further-information contacts are Toyin Momoh, Senior Counsel, and Thomas Ahmadifar, Branch Chief, Division of Investment Management, Chief Counsel's Office, at (202) 551-6825; and the notice directs readers to the application itself, filed 2 July 2026, on the Commission's EDGAR system for the applicants' representations, legal analysis and conditions. A discrepancy internal to the document is noted rather than resolved: the caption reads Baillie Giffords Funds while the Applicants line reads Baillie Gifford Funds, and this brief uses the Applicants line. The notice does not state whether the Commission has granted comparable relief to any other applicant, does not name any other applicant, does not state any asset figure, fee, launch date or fund name, and does not contain the applicants' representations or the conditions attaching to the order, all of which the notice says are in the application on EDGAR. None of those things is asserted below. The notice contains no allegation of conduct against any party..