Ares Sports, Media & Entertainment (ASME): NAV, Oct 30 Deadline
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Quick Answer
Ares Sports, Media and Entertainment Opportunities LP (ASME, CIK 2046946) reported a Transactional NAV of $28.56 per Class A-S unit, $28.80 per Class I unit and $29.46 per Class E unit at September 30, 2026, on an aggregate Transactional NAV of about $988 million (Form 8-K dated October 21, 2026, accession 0001628280-26-066723). It is a Delaware limited partnership and a private fund under Section 3(c)(7) of the Investment Company Act, open only to investors who are both accredited investors and qualified purchasers. The next redemption date is December 31, 2026, and the Form 10 says requests are accepted until 4:00 p.m. ET on the last business day of the first month of the quarter, which is Friday, October 30, 2026 (our reading of that rule). Units held under 18 months lose 5% of NAV, and the program caps redemptions at 3% of NAV per quarter, about $29.6 million on the September 30 NAV (our arithmetic). The two windows so far took $25 thousand and $1.1 million.
Key Takeaways
- The deadline: the Form 10 amendment of December 15, 2025 says the Fund expects to accept requests no later than 4:00 p.m. ET on the last business day of the first month of the quarter, about 60 days before quarter end. For the December 31, 2026 redemption date that is Friday, October 30, 2026. The 10-Qs do not restate the deadline, and the Form 10 calls its dates illustrative, so confirm with your intermediary.
- You will not know the price when you ask. The redemption price is the Transactional NAV at the redemption date, and the Form 10 says holders will not know it at the time of the request. Unfilled requests are not carried over: you must resubmit next quarter.
- Most units still pay the 5% deduction. The 18 months are counted to the subscription closing after the redemption date (January 1, 2027), so only units bought on or before July 1, 2025 escape it. The Fund had 14.2 million units at September 30, 2025 and 30.6 million at June 30, 2026, so at least 53.5% of the June 30 units were issued later and pay it (our arithmetic).
- Exits have been tiny, so the 3% cap has never been tested: $25 thousand redeemed for the March 31, 2026 date and $1.1 million for June 30, about 5% of that quarter’s cap (our arithmetic). The September 30 result is not public yet.
- The price on the screen is not the accounting NAV. At June 30, 2026 GAAP net assets were $827.9 million and Transactional NAV $867.9 million, a $40.0 million gap: $25.0 million of servicing fees that GAAP books up front and $14.9 million of start-up costs that the price spreads over 60 months.
- Money in jumped in October mostly because of one class: the October 1 sale was $77.0 million, but $43.5 million (56.5%) went into Class E, which the Form 10 reserves mainly for Ares people and Ares funds. Without it, October was $33.5 million, 28.7% below September’s $47.0 million (our arithmetic).
- No cash comes back: the Fund had declared no distributions through June 30, 2026. Of the $44.7 million nine-month increase in net assets, $11.7 million was net investment income and $27.9 million was unrealized gain net of deferred tax (our arithmetic), and the Form 10 warns that taxable income can exceed cash distributions.
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Ares Sports, Media and Entertainment Opportunities LP: monthly NAV by class, unit sales, redemption terms, GAAP bridge, fees and portfolio, 2025-2026
248 rows read from the Form 10 amendment, three 10-Qs and eleven monthly 8-Ks of Ares Sports, Media and Entertainment Opportunities LP: NAV for nine classes at eleven month-ends, unit sales by class, redemption terms and windows, the GAAP-to-Transactional NAV bridge, fees and portfolio.
What ASME is, and what the filings say about who can hold it
Ares calls the strategy SME Opps. The legal vehicle is Ares Sports, Media and Entertainment Opportunities LP, which the 10-Q describes as “a private fund exempt from registration pursuant to Section 3(c)(7) of the Investment Company Act of 1940,” structured “as a perpetual-life vehicle, with monthly, fully-funded subscriptions and periodic redemptions.” Its manager, Ares Capital Management LLC, is a subsidiary of Ares Management Corporation (Form 10-Q, accession 0001628280-26-057135). The objective is “long-term capital appreciation, and to a lesser extent” income, through debt, preferred and common equity in sports leagues, teams and related companies, plus media and entertainment. Our page on Ares Management Corporation covers the sponsor; this page covers the fund.
Three things readers assume, and what the documents say:
- It is not a BDC and not an interval fund. It files 10-Ks, 10-Qs and 8-Ks because it registered units under the Exchange Act (Form 10, file number 000-56791), not because it sold a registered product. There is no prospectus.
- It is not open to every accredited investor. Every monthly 8-K says units are sold to investors that are both accredited investors and qualified purchasers, a higher bar explained on our page on qualified purchaser vs accredited investor.
- Part of the money sits in a feeder. Units are also sold “through Ares SME O TE LP,” a Delaware limited partnership, for “tax-exempt investors and non-U.S. investors” (Form 8-K, accession 0001628280-26-066723). Those investors hold through the Feeder and its offshore blockers, and the Form 10 says the Early Redemption Deduction will not be applied to feeder or parallel-fund investors.
The Fund started investing on December 6, 2024 and took its first outside money on June 1, 2025. It reports on a September 30 fiscal year, which is why its 10-Qs are for the quarters ending December 31, March 31 and June 30 and its first 10-K should cover the year to September 30, 2026 (our reading).
Nine classes, and what each costs
The Fund has nine classes. The “A” classes are Anchor Units, offered to institutions and anchor intermediaries that subscribed at least $15 million at the first closing they joined, in the closings of June 1, July 1, August 1 and September 1, 2025, and the General Partner may offer them to others. Class E pays no management fee, servicing fee or performance allocation. Fee terms from the Form 10 amendment and the June 30 10-Q:
| Class | Management fee (per year of NAV) | Servicing fee | Performance allocation | Upfront fee cap (charged by intermediary) | Standing fees before performance (our sum) |
|---|---|---|---|---|---|
| S | 1.40% | 0.85% | 15% of total return over 5% hurdle | 3.5% | 2.25% |
| N | 1.40% | 0.50% | 15% over 5% hurdle | 2.0% | 1.90% |
| D | 1.40% | 0.25% | 15% over 5% hurdle | 2.0% | 1.65% |
| I | 1.40% | None | 15% over 5% hurdle | None | 1.40% |
| A-S (Anchor) | 1.25% | 0.85% | 12.5% over 5% hurdle | 3.5% | 2.10% |
| A-N (Anchor) | 1.25% | 0.50% | 12.5% over 5% hurdle | 2.0% | 1.75% |
| A-D (Anchor) | 1.25% | 0.25% | 12.5% over 5% hurdle | 2.0% | 1.50% |
| A-I (Anchor) | 1.25% | None | 12.5% over 5% hurdle | None | 1.25% |
| E | None | None | None | None | None |
The performance allocation carries a high water mark and a 100% catch-up, is measured by calendar year and accrues monthly (Form 10-Q). Both the management fee and the performance allocation were waived through December 31, 2025, so 2026 is the first year the Fund charges them in full. In the nine months to June 30, 2026 the Fund incurred a gross management fee of $6.3 million ($1.7 million waived), a performance allocation of $7.0 million ($0.9 million waived) and servicing fees of $17.2 million, $30.5 million in all (our sum). The performance allocation was 1.12 times the management fee (our arithmetic). Class E at $29.46 against Class A-I at $28.89 and Class S at $28.52 is what those fees look like in the price: E is 2.0% above A-I and 3.3% above S at September 30, 2026 (our arithmetic).
Money in: $454.8 million in eleven monthly sales
Each month’s Item 3.02 8-K gives the units sold on the first of the month by class. The price of each sale is the prior month-end Transactional NAV, and the unit counts are final only after that NAV is struck (the October 1 sale was finalized on October 21, 2026).
| Sale date | Sold (company figure) | Cumulative issued to date (company figure) | Class E in the sale | 8-K accession |
|---|---|---|---|---|
| Dec 1, 2025 | $57.8M | $591M | none | 0001104659-25-123783 |
| Jan 1, 2026 | $47.7M | $639M | none | 0002046946-26-000004 |
| Feb 1, 2026 | $25.2M | $664M | none | 0002046946-26-000010 |
| Mar 1, 2026 | $39.8M | $704M | none | 0001628280-26-020170 |
| Apr 1, 2026 | $38.1M | $742M | none | 0001628280-26-026305 |
| May 1, 2026 | $27.5M | $769M | none | 0001628280-26-037733 |
| Jun 1, 2026 | $34.2M | $804M | none | 0001628280-26-045513 |
| Jul 1, 2026 | $30.1M | $834M | none | 0001628280-26-049002 |
| Aug 1, 2026 | $30.4M | $864M | none | 0001628280-26-058433 |
| Sep 1, 2026 | $47.0M | $911M | none | 0001628280-26-062890 |
| Oct 1, 2026 | $77.0M | $988M | $43.5M (1,477,627 units) | 0001628280-26-066723 |
The eleven sales add to $454.8 million, an average of $41.3 million a month, or $37.8 million excluding October (our sums). The cumulative figures reconcile to the monthly sales to within rounding. The October sale is the story: $77.0 million is the largest in the series, and $43.5 million of it, 56.5%, is Class E, which the Form 10 says is “generally available for purchase only by” the Fund’s officers and directors, Ares, its affiliates and their employees, advisory board members, “Other Ares Funds,” and other categories the Fund names. The 8-K does not say who bought. Excluding Class E, October was $33.5 million, 28.7% below September’s $47.0 million (our arithmetic). No earlier monthly 8-K in the series shows any Class E sale.
Cumulative issuance of $988 million and an aggregate Transactional NAV of about $988 million are two different measures that happen to match: the first includes the October 1 sale, the second is the September 30 value before it. Pro forma for October the Fund is about $1.07 billion (our arithmetic).
NAV by class: $26.53 to $28.89, and Class E pulls away
The monthly 8-K gives a Transactional NAV for each class about three weeks after month end (the September 30 figure came on October 21). Subscriptions are priced at the prior month-end NAV, so this is also the price new buyers paid. The September 30, 2025 row is from the Form 10 amendment, which printed only the totals and the Class A-I and E figures we use here.
| Month-end | Class S | Class A-S | Class I | Class A-I | Class E | Aggregate Transactional NAV (company figure) | Filing accession |
|---|---|---|---|---|---|---|---|
| Sep 30, 2025 | n/a | n/a | n/a | $26.53 | $26.53 | $377.3M | 0001104659-25-121226 |
| Nov 30, 2025 | $26.71 | $26.70 | $26.81 | $26.81 | $26.81 | about $556M | 0001104659-25-123783 |
| Dec 31, 2025 | $27.02 | $27.00 | $27.14 | $27.14 | $27.14 | about $621M | 0002046946-26-000004 |
| Jan 31, 2026 | $27.03 | $27.02 | $27.17 | $27.17 | $27.20 | about $669M | 0002046946-26-000010 |
| Feb 28, 2026 | $26.99 | $26.98 | $27.15 | $27.15 | $27.21 | about $693M | 0001628280-26-020170 |
| Mar 31, 2026 | $27.92 | $27.94 | $28.09 | $28.13 | $28.40 | about $759M | 0001628280-26-026305 |
| Apr 30, 2026 | $28.02 | $28.05 | $28.22 | $28.27 | $28.58 | about $801M | 0001628280-26-037733 |
| May 31, 2026 | $28.13 | $28.14 | $28.32 | $28.38 | $28.74 | about $832M | 0001628280-26-045513 |
| Jun 30, 2026 | $28.20 | $28.22 | $28.41 | $28.48 | $28.88 | about $868M | 0001628280-26-049002 |
| Jul 31, 2026 | $28.26 | $28.28 | $28.49 | $28.57 | $29.02 | about $900M | 0001628280-26-058433 |
| Aug 31, 2026 | $28.30 | $28.33 | $28.55 | $28.63 | $29.13 | about $933M | 0001628280-26-062890 |
| Sep 30, 2026 | $28.52 | $28.56 | $28.80 | $28.89 | $29.46 | about $988M | 0001628280-26-066723 |
Class A-I rose 8.9% from $26.53 at September 30, 2025 to $28.89 a year later, and Class E 11.0% (our arithmetic). Over the ten months from November 30, 2025, Class S gained 6.8%, Class A-S 7.0% and Class I 7.4%. The path was not smooth: the NAV slipped in February 2026 (Class S down 0.15%), then jumped 3.4% in March (Class S from $26.99 to $27.92). The 10-Q explains the rhythm: in months that are not quarter-ends the manager “will generally value such assets at the most recent quarterly valuation” unless it sees a significant observable change, so quarter-end months carry the repricing. The company’s own returns at June 30, 2026 were 6.65% for Class A-S, 7.07% for Class I and 8.86% for Class E for the nine months, and 12.87%, 12.20% and 15.53% since inception (Form 10-Q). The July-September 2026 quarter added 1.2% for Class A-S, 1.4% for Class I and 2.0% for Class E, and September alone added 0.8% for Class A-S (our arithmetic from the 8-Ks). The value is set by the manager under its valuation policy, and the fund is not traded, so there is no market price to check it against.
Two NAVs: the price you transact at is $40 million above the accounting NAV
Transactional NAV is, in the 10-Q’s words, “the price at which transactions in the Units are made.” It differs from the GAAP NAV in the financial statements, and the 10-Q reconciles the two. The gap is two items:
| Date | GAAP net assets | Add: start-up costs spread over 60 months | Add: servicing fees GAAP books up front | Transactional NAV | Gap vs GAAP (our arithmetic) |
|---|---|---|---|---|---|
| Dec 31, 2025 | $589.6M | $12.0M | $19.0M | $620.6M | $31.0M (5.3%) |
| Mar 31, 2026 | $723.3M | $13.2M | $23.0M | $759.5M | $36.2M (5.0%) |
| Jun 30, 2026 | $827.9M | $14.9M | $25.0M | $867.9M | $40.0M (4.8%) |
The first item is organizational and offering costs that the manager advanced: the price recognizes them “ratably over 60 months, beginning on June 1, 2026” (Form 8-K, October 21, 2026). The second is servicing fees: under GAAP the cost is accrued “for the estimated life of the Units” when the fee-paying classes are issued, while the price takes the fee month by month. The balance sheet at June 30, 2026 shows $25.4 million of servicing fees payable. The effect by class is large for the fee-paying classes: Class S was $26.29 on the GAAP balance sheet and $28.20 on the Transactional NAV, 6.8% less, and Class A-S $26.31 against $28.22; for the fee-free Class E it was $28.39 against $28.88, 1.7% less (our arithmetic). A seller of Class S is paid the higher number; the holder who stays carries the servicing fees still to come. The 8-K also notes that “certain contingent tax liabilities may not be recognized” in Transactional NAV if the General Partner expects they will not be incurred when an investment is sold; the 10-Q shows a deferred tax liability of $9.0 million at June 30, 2026.
The redemption window: October 30, 2026 for the December 31 date
The rules come from two documents. The Form 10 amendment of December 15, 2025 sets the mechanics; the 10-Qs repeat the cap and the deduction but not the timing. The Form 10 says the Fund “expects that it will accept redemption requests and required documentation no later than 4:00 p.m. ET on the last Business Day of the first month of the applicable calendar quarter,” which it describes as “approximately 60 calendar days prior to the end of the applicable calendar quarter.” For the quarter ending December 31, 2026 the first month is October, and its last business day is Friday, October 30, 2026 (October 31 is a Saturday). That is 62 days before December 31 (our arithmetic). We checked the latest 10-Q (August 14, 2026) for a changed date and found none, but it does not restate the deadline either, so the date rests on the Form 10 alone. The Form 10 also says the dates “are meant to be illustrative,” so the operative date is the one your intermediary or the Fund’s administrator gives you, and an intermediary may set an earlier internal cutoff.
What the rules say, in order of what surprises people:
- You do not know the price. Redemptions are paid at the Transactional NAV on the redemption date (December 31), and “Unitholders will not know the NAV per Unit on the Redemption Date or at the time their redemption request is made.” The October 30 request is priced against a NAV that will not be published until about three weeks after year end.
- Money arrives in about 35 days. Settlement is “approximately 35 calendar days after the Redemption Date,” which points to about February 4, 2027 (our arithmetic).
- The cap is 3% a quarter. The Fund expects to redeem “up to 3% of Units outstanding (by aggregate NAV) measured as of the close of the previous calendar quarter.” On the September 30 NAV of about $988 million that is about $29.6 million (our arithmetic). If requests exceed it, they are filled pro rata after death and qualifying-disability requests, and “unsatisfied redemption requests will not be automatically carried over to the next redemption period.”
- The General Partner can change it. It “may amend or suspend” the program if it judges that in the Fund’s best interest, with Independent Director approval for a material change, and the Fund has “no obligation to redeem Units” where federal or Delaware law restricts distributions.
- Exchanges between classes for equal value do not count toward the 3% and do not pay the deduction.
| Redemption date | Request deadline (our reading of the Form 10 rule) | Cap at 3% of prior quarter-end NAV (our arithmetic) | Redeemed (10-Q) | Share of cap used (our arithmetic) |
|---|---|---|---|---|
| Mar 31, 2026 | Fri, Jan 30, 2026 | about $18.6M (on $620.6M) | 1,000 units, $25 thousand (average $26.54) | 0.13% |
| Jun 30, 2026 | Thu, Apr 30, 2026 | about $22.8M (on $759.5M) | 34,000 units, $1.1 million; all requests paid in full | 5.0% |
| Sep 30, 2026 | Fri, Jul 31, 2026 | about $26.0M (on $867.9M) | Not public yet: the 10-K for the year to Sep 30, 2026 | unknown |
| Dec 31, 2026 | Fri, Oct 30, 2026 | about $29.6M (on $988M) | Window open until Oct 30 | unknown |
One inconsistency in the June 30 10-Q: the financial statements and the MD&A say 34,000 units were redeemed in the quarter for $1.1 million ($1,143 thousand), while the Item 2 table lists 14 thousand units at an average $28.44. The dollars match the 34,000 figure, not 14,000 at $28.44 (about $0.4 million, our arithmetic), so we use the $1.1 million. No redemptions were possible in the first quarter of the fiscal year: the program began with the first calendar quarter of 2026.
Who pays the 5%
Units outstanding “fewer than 18 months” lose 5% of their Transactional NAV at the redemption date. The Form 10 measures the 18 months “as of the subscription closing date immediately following the prospective redemption date” and gives an example: units bought on June 1 pay nothing in a program with a December 31 valuation date the following year. Applying that rule to each date (our arithmetic, and our reading of the boundary):
| Redemption date | Next subscription closing | Units bought on or before this sale date avoid the 5% |
|---|---|---|
| Dec 31, 2026 | Jan 1, 2027 | Jul 1, 2025 |
| Mar 31, 2027 | Apr 1, 2027 | Oct 1, 2025 |
| Jun 30, 2027 | Jul 1, 2027 | Jan 1, 2026 |
| Sep 30, 2027 | Oct 1, 2027 | Apr 1, 2026 |
| Dec 31, 2027 | Jan 1, 2028 | Jul 1, 2026 |
The Fund had 14.2 million units at September 30, 2025 and 30.6 million at June 30, 2026 (Form 10 and Form 10-Q). Some of the first 14.2 million were issued on August 1 and September 1, 2025 and are inside the 18 months at December 31, 2026, so at most 46.5% of the June 30 units escape the deduction and at least 53.5% pay it (our arithmetic). Units from the distribution reinvestment plan never pay it, and there have been no distributions to reinvest. The General Partner may also waive the deduction for death, disability, model-portfolio rebalancing and operational errors. Worked example (our arithmetic, illustrative because the redemption NAV is unknown): 10,000 Class A-I units bought after August 1, 2025, valued at September 30’s $28.89, are $288,900; the 5% deduction is $14,445, leaving $274,455 if the NAV did not move.
The sports-league clause
The Form 10 lets the General Partner require a holder to withdraw, in whole or part, where a “Sports League Adverse Effect” is likely. It defines that as “a significant impairment, delay or other negative impact on the ability of the Fund or any Intermediate Entity to acquire or own an investment” in a sports league, team or franchise attributable to a holder’s status as a limited partner or to a violation of a league rule. Transfers can also be refused if they “violate or be inconsistent with any applicable sports league rules.” No filing says the clause has been used. It matters because the Fund’s stated theme is sports leagues and teams, which have ownership rules of their own, and it means a holder’s exit is not entirely the holder’s choice.
What it owns, what it earned, and how it is funded
At June 30, 2026 the Fund had 35 portfolio companies in targeted sports, media and entertainment investments with a fair value of about $599 million, plus 133 investments in liquid debt and other securities worth about $256 million (Form 10-Q). The liquid sleeve is 29.9% of the $855 million of investments (our arithmetic). Of the targeted book, 77% is sports, media and entertainment and 15% consumer services; by instrument 47% is common equity, 26% first-lien loans and 20% preferred equity. The March 31 filing showed 31 companies and $547 million, with 76% in sports, media and entertainment. The December 31, 2025 filing counted 106 portfolio companies and $589 million under a different definition, so the two counts are not comparable.
The earnings are mostly unrealized. For the nine months to June 30, 2026 the Fund reported total investment income of $27.8 million, net investment income of $11.7 million, net unrealized gains on investments of $36.6 million, a $8.7 million charge for the change in deferred tax liabilities, and a net increase in net assets of $44.7 million (Form 10-Q). Net investment income was 26% of that increase and unrealized gains net of the deferred tax charge 62% (our arithmetic). Nothing has been paid out: the 10-Q says “We did not declare or pay any distributions from inception through June 30, 2026,” and the Form 10 says the Fund “does not expect to make distributions on a regular basis.”
On leverage, the Fund had no debt at June 30, 2026 (it had $24 million at September 30, 2025). On March 27, 2026 three subsidiaries signed a $250 million senior secured revolver with JPMorgan Chase Bank at SOFR plus 1.50% to 3.27%, with a commitment fee of 0.50% to 1.50% on unused amounts; nothing was drawn at June 30. Cash was $58.4 million. The Fund had two earlier lines, with U.S. Bank and City National Bank, which ended in November 2025. A drawdown on the revolver to meet redemptions would be visible in the next 10-Q or 10-K.
Tax
ASME is a partnership, so holders receive a Schedule K-1 (see our guide to K-1 boxes for real estate and private funds and the page on estimated tax payments on K-1 income). The Form 10 warns that “there may be delays in distributing important tax information to investors (including the distribution of U.S. Schedule K-1s or their equivalent),” and that the Fund may generate taxable income in excess of cash distributions and “does not expect to make cash distributions to cover such tax liabilities as they arise.” Investors who cannot absorb a tax bill with no cash behind it should settle that before buying, not after.
What a holder can do with this
- If you hold and are thinking of redeeming: the deadline for the December 31, 2026 date is, on the Form 10 rule, October 30, 2026 at 4:00 p.m. ET. Ask your intermediary for its own cutoff today. Your price will be the December 31 Transactional NAV, unknown on October 30, less 5% if your units were bought after July 1, 2025. If the request is cut back by the 3% cap, it is not carried over. Check the purchase date of each lot of units on your statement.
- If you are comparing it with other evergreen funds: the table of every program is in our page on evergreen fund redemptions compared, and the closest sibling from the same sponsor is Ares Private Markets Fund. The guide to what an evergreen fund is explains the structure, and the platform comparison shows where funds like this are distributed.
- If you are choosing a class: the fee table decides it. Class S costs 2.25% a year in standing fees before performance and Class I 1.40%, and the S class adds an upfront fee up to 3.5% through the intermediary (our sums). The Anchor classes are 0.15 points cheaper but were aimed at institutions and anchor intermediaries in 2025. Class E has no fees and is not for the public.
- What would change the picture (our thresholds, not the company’s): a monthly sale below $25 million, a Class E share above half of a month’s sales again, a redemption window above 1% of NAV, a drawdown on the revolver, or a change to the program in an 8-K. On the pattern of the last eleven filings, the 8-K for October 31 should appear about November 20 and the one for November 30 about December 21.
- What to read next: the 10-K for the year to September 30, 2026, which should carry the September 30 redemption result, and the next 10-Q for the December 31 window.
FAQ
Filing alert · free
An email when Ares Sports, Media and Entertainment Opportunities (ASME) files with the SEC
When Ares Sports, Media and Entertainment Opportunities (ASME) files: what changed, the one number that matters, and the accession number to check it yourself.
All figures are from SEC filings of Ares Sports, Media and Entertainment Opportunities LP (CIK 2046946) read on EDGAR on October 23, 2026: Amendment No. 1 to the Form 10 (accession 0001104659-25-121226, filed December 15, 2025), Forms 10-Q for December 31, 2025 (0002046946-26-000007), March 31, 2026 (0001628280-26-035578) and June 30, 2026 (0001628280-26-057135), and the monthly Form 8-Ks of December 22, 2025 to October 21, 2026 for unit sales (Item 3.02) and NAV, with accession numbers in the tables and the dataset. Cumulative sums, percentage changes, class comparisons, the redemption caps, the request-deadline dates, the 18-month boundary dates and the worked example are our arithmetic. The October 30 deadline is our reading of the Form 10 rule. This is analysis of public documents, not investment, legal or tax advice.
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