In accordance with Rule 35d‑1 under the 1940 Act, under normal circumstances, the Fund will not invest less than 80% of the value of its net assets, plus the amount of any borrowings for investment purposes, in components of its Underlying Index. Investments in derivatives and other investments will be counted toward the Fund’s 80% investment policy to the extent that they provide exposure to the components of its Underlying Index or exposure to one or more market risk factors associated with such components. The Fund’s 80% investment policy may be changed by the Company’s Board of Trustees (the “Board”) upon 60 days’ notice to shareholders.
The Commodity Futures Trading Commission (“CFTC”) has adopted certain requirements that subject registered investment companies and their advisers to regulation by the CFTC if a registered investment company invests more than a prescribed level of its net asset value in CFTC-regulated futures, options and swaps, or if a registered investment company markets itself as providing investment exposure to such instruments. Due to the Fund’s potential use of such instruments above the prescribed levels, it is considered a “commodity pool” under the Commodity Exchange Act (“CEA”). The Subsidiary is also deemed a commodity pool. BFA is considered a commodity pool operator (“CPO”) with respect to the Fund and the Subsidiary and is subject to regulation by the CFTC and the National Futures Association (“NFA”).
The Underlying Index is sponsored by the Index Provider, which is independent of the Fund and BFA. The Index Provider determines the composition and relative weightings of the components of the Underlying Index and publishes information regarding the market value of the Underlying Index.
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The subsection entitled “The Bloomberg Roll Select Commodity Total Return Index” in the section entitled Construction and Maintenance of the Underlying Indexes in the Fund’s SAI is deleted in its entirety and replaced with the following: |
The Bloomberg Enhanced Roll Yield Total Return Index
The Bloomberg Enhanced Roll Yield Total Return Index (the “Underlying Index”) measures the performance of a long-only basket of liquid commodity futures contracts across six physical commodity groups, including energy, precious metals, industrial metals, grains and derived grains, softs, and livestock, as determined by Bloomberg Index Services Limited (“Bloomberg” or the “Index Provider”). The Underlying Index, which is rebalanced annually, provides a broad-based exposure to commodities as an asset class by using liquidity factors and sector caps to avoid over-concentration in any single commodity or commodity sector.
The Underlying Index employs a multi-contract roll schedule to spread risk across three to four futures contracts per commodity, e.g., three futures contracts per precious metal commodity and four futures contracts per commodity in all other commodity groups, with a roll period of ten business days. The Underlying Index rolls and rebalances these contracts monthly back to equal weightings on a price-percentage basis.
To construct the Underlying Index, the Index Provider calculates the liquidity percentage and slope scores for each commodity using trading volumes and historic U.S. dollar values of each futures contract within the volume horizon, and then applies the following capping:
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No single commodity (e.g., natural gas, silver) may constitute more than 15% of the Index; |
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No related group of commodities (e.g., energy, precious metals, livestock, or grains & derived grains) may constitute more than 33% of the Index; |
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No single commodity (e.g., natural gas, silver) may constitute less than 1.5% of the Index as liquidity allows. |
Such capping may be exceeded by the commodity target weight calculated for each commodity on the last Underlying Index business day of November for the following year and implemented at the January Roll Period with the regular monthly roll and rebalance of the Underlying Index.
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The section entitled Non‑Fundamental Investment Policies of the Fund in the Fund’s SAI is deleted in its entirety and replaced with the following: |
Non‑Fundamental Investment Policies of the Fund
Under its non‑fundamental investment restrictions, which may be changed by the Board without shareholder approval, the Fund may not purchase shares of any registered open‑end investment company or registered unit investment trust, in reliance on Section 12(d)(1)(F) or (G) of the Investment Company Act, at any time the Fund has knowledge that its shares are purchased by another investment company investor in reliance on the provisions of subparagraph (G) of Section 12(d)(1). The foregoing restriction does not restrict the Fund from acquiring the shares of registered open‑end investment companies to the extent otherwise permissible under other provisions of the 1940 Act, as interpreted, modified or otherwise permitted by regulatory authority having jurisdiction, from time to time.
Notations Regarding the Fund’s Fundamental and Non‑Fundamental Investment Policies
Unless otherwise indicated, all limitations under the Fund’s fundamental or non‑fundamental investment restrictions apply only at the time that a transaction is undertaken. Any change in the percentage of the Fund’s assets invested in certain securities or other instruments resulting from market fluctuations or other changes in the Fund’s total assets will not require the Fund to dispose of an investment.
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