Dodge & Cox applies to add ETF share classes to its funds

Dodge & Cox filed an application with the SEC on 2 October seeking exemptive relief. The relief would let funds advised by the firm offer an exchange-traded share class alongside conventional mutual fund classes.

What is being requested

The application asks for an order allowing a fund to offer one class of exchange-traded shares, the “ETF Class”, and one or more classes that are not exchange-traded, the “Mutual Fund Classes”. It cites recent precedent, including an order granted to DFA Investment Dimensions Group in November 2025, which it calls the “Dimensional Order”. It also cites four earlier orders granted to Vanguard entities between 2000 and 2007, each preceded by a public notice.

The stated rationale

The applicants argue that an ETF class added to an existing fund could benefit from that fund’s pre-existing assets and performance. They add that mutual fund classes within an existing ETF could open another distribution channel. The filing points to retirement plans: 401(k) plans “may not offer ETFs to their plan participants”. Under the requested relief, mutual fund shares of a multi-class ETF fund could be made available on those platforms.

Other applicants

Dodge & Cox was not the only applicant in the period. Grandeur Peak Global Trust and Grandeur Peak Global Advisors filed a similar application on 2 October, and Arrow Investments Trust, Arrow ETF Trust and Arrow Investment Advisors filed an amended application on 9 October. Both seek orders for an “ETF Class” and “Mutual Fund Class” structure.

Why it matters

An application is a request, not an approval. In the precedents the application cites, the SEC published a notice before issuing each order. Each filing nonetheless adds to the list of managers asking to run ETF and mutual fund share classes within a single portfolio.

Added to The Midpoint on 31 October 2026, with the ETFs section. This article is dated to the event it describes; it was not published at the time.

Sources

• Application for exemptive relief under Sections 6(c) and 17(b) (Form 40-APP), Dodge & Cox Funds via SEC EDGAR, 2 Oct 2026
• Application for exemptive relief (Form 40-APP), Grandeur Peak Global Trust via SEC EDGAR, 2 Oct 2026
• Application for exemptive relief (Form 40-APP), Arrow Investments Trust via SEC EDGAR, 9 Oct 2026