External Meetings: Meeting w/Steben & Co.

The meeting focused on mutual funds that operate managed futures strategies. Specifically, the meeting participants discussed three issues: (1) whether, as a policy matter, U.S. investors and derivatives products are best served by investment structures that require the diversion of assets to a controlled foreign corporation ("CFC"); (2) whether registered investment companies ("RICs") offering managed futures strategies are being made to disclose sub-advisor compensation in their prospectuses to U.S. investors; and (3) whether managed futures strategies operated inside of (RICs) require a leverage ratio that is disproportionate to that of a (non-RIC) commodity pool.~The issues that Steben & Co. addressed during this meeting are thoroughly covered in the company's April 12, 2011 comment letter, which is available on the Commission's website.