N-CSR 1 d250379dncsr.htm ARGA Arga

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM N-CSR

 

 

CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT

INVESTMENT COMPANIES

Investment Company Act File Number 811-22920

 

 

The Advisors’ Inner Circle Fund III

(Exact name of registrant as specified in charter)

 

 

SEI Investments

One Freedom Valley Drive

Oaks, PA 19456

(Address of principal executive offices) (Zip code)

 

 

SEI Investments

One Freedom Valley Drive

Oaks, PA 19456

(Name and address of agent for service)

 

 

Registrant’s telephone number, including area code: (877) 446-3863

Date of fiscal year end: December 31, 2021

Date of reporting period: December 31, 2021

 

 

 


Item 1.

Reports to Stockholders.

A copy of the report transmitted to stockholders pursuant to Rule 30e-1 under the Investment Company Act of 1940, as amended (the “Act”) (17 CFR § 270.30e-1), is attached hereto.


The Advisors’ Inner Circle Fund III

 

LOGO

Emerging Markets Value Fund

International Value Fund

 

  ANNUAL REPORT

   DECEMBER 31, 2021  

 

 

Investment Adviser:

ARGA Investment Manager, LP


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021

 

 

TABLE OF CONTENTS

 

 

Letter to Shareholders

     1  

Schedules of Investments

     10  

Statements of Assets and Liabilities

     18  

Statements of Operations

     19  

Statements of Changes in Net Assets

     20  

Financial Highlights

     22  

Notes to Financial Statements

     24  

Report of Independent Registered Public Accounting Firm

     36  

Trustees and Officers of the Advisors’ Inner Circle Fund III

     38  

Disclosure of Fund Expenses

     44  

Notice to Shareholders

     46  

The Funds file their complete schedules of investments with the Securities and Exchange Commission (“SEC”) for the first and third quarters of each fiscal year as an exhibit to its reports on Form N-PORT. The Funds’ Form N-PORT reports are available on the SEC’s website at http://www.sec.gov, and may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330.

A description of the policies and procedures that the Funds use to determine how to vote proxies relating to fund securities, as well as information relating to how the Fund voted proxies relating to fund securities during the most recent 12-month period ended June 30, is available (i) without charge, upon request, by calling 1-866-392-2626; and (ii) on the SEC’s website at http://www.sec.gov.

 


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

Dear Shareholders,

ARGA appreciates the opportunity to review performance of the ARGA Emerging Markets Fund (Fund) from inception on 6/3/2021 to 2021 year-end.

Over the short period, the Fund declined 8.5% (net). The MSCI Emerging Markets Index was down 9.7%, compared to a 6.5% decrease in the MSCI Emerging markets Value.

The Fund’s modest outperformance was driven, yet limited, by market factors in combination with our long-term valuation-oriented approach. Over the period, ARGA took advantage of market swings to own deeply undervalued stocks, which we believe have substantial upside.

Fund inception occurred after a rise in emerging markets equities over the first five months of 2021. During that period before inception, emerging markets investors were broadly optimistic over improving global growth outlook and vaccine rollouts. Soon after Fund inception, in June 2021, investor optimism was dashed by a third COVID wave with two variants. Emerging markets declined on new concerns over supply chain issues, inflation, regulatory tightening mostly in China, Chinese property market turmoil, and geopolitical risks evidenced by Russian aggression toward Ukraine.

The market downswing in the second half of the year enabled the Fund to purchase many attractively valued stocks of solid businesses with good balance sheets that we expect to emerge stronger. Throughout the period, ARGA maintained strict adherence to our disciplined valuation process. Historically, strict adherence across diverse investing environments leads to periods when portfolio results may widely fluctuate from market indices. Over time, we believe the process optimizes portfolio returns.

The Fund’s value style approach is based on the core belief that investment opportunity results from investor reaction to stress (macro or company). The overreaction reflects investor behavioral biases such as need for certainty. As temporary stress disproportionately impacts valuations, this creates pricing anomalies. Value investors such as ARGA can take advantage of these anomalies to purchase good companies at discounted prices. As conditions recover over time, we expect the stocks to recover.

Fund performance reflected mixed impacts on certain sectors and companies. Utilities and Energy were the largest sector contributors to results. The favorable Utilities contribution was primarily due to strong performance by a large China power company that benefitted from its renewables investments, especially wind power. Energy holdings recovered on higher energy prices, disciplined industry capex, and company initiatives to reduce production costs, improve mix, and divest low-return assets.

Partial performance offsets included drag from Consumer Discretionary and Technology sectors. Consumer Discretionary detractors included a Macau gaming company and China’s largest ecommerce company, both pressured by Chinese regulatory tightening. With solid business models and market advantages, both are expected to recover over time. Technology dragged largely from the absence of highly priced tech companies, which benefitted from supply shortages.

 

1


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

Activity during the period well positions the Fund for future returns. Opportunities for valuation recovery span a range of sectors and geographies. Many are company specific. Areas of undervaluation identified by ARGA Research include:

 

 

Select Chinese internet companies, reeling from investor overreaction to China regulatory risk, yet likely to generate strong cash flows

 

Macau gaming companies, where leaders in the growing and highly profitable mass segment should profit as visitations recover

 

Diversified mix of Financials with strong earnings potential: bank holdings well capitalized to weather near-term credit losses; and insurance holdings with strong market positions and resilient earnings.

Valuation spreads in emerging markets remain wide. Current spreads between the cheapest and most expensive stocks are far above historical averages. Historically, high spreads have signaled subsequent value outperformance. ARGA Research confirms the Fund should generate strong returns.

Thank you for investing with ARGA.

ARGA Portfolio Construction Team

The material represents the manager’s assessment of the portfolio and market environment at a specific point in time and should not be relied upon by the reader as research or investment advice regarding any stock. Neither this material nor any accompanying oral presentation or remarks by a representative is intended to constitute a recommendation of the Fund or a determination of suitability.

Portfolio holdings are subject to change and should not be considered investment advice or a recommendation to buy securities.

Index performance returns do not reflect any management fees, transaction costs or expenses. Indexes are unmanaged and one cannot invest directly in an index. Past performance does not guarantee future results.

 

2


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

Dear Shareholders,

ARGA appreciates the opportunity to review performance of the ARGA International Value Fund (Fund) from inception on 6/3/2021 to 2021 year-end.

Over the short period, the Fund declined 7.2% (net). The MSCI ACWI ex US Index was down 2.4%, compared to a 3.7% decrease in the MSCI ACWI ex US Value Index.

The Fund’s underperformance was driven by market factors in combination with our long-term valuation-oriented approach. Over the period, ARGA took advantage of market swings to own deeply undervalued stocks, which we believe have substantial upside.

Fund inception occurred after a rise in international equities over the first five months of 2021. During that period before inception, international investors were broadly optimistic over improving global growth outlook and vaccine rollouts. Soon after Fund inception, in June 2021, investor optimism was dashed by a third COVID wave with two variants. Markets declined on new concerns over supply chain issues, inflation, regulatory tightening mostly in China, and geopolitical risks evidenced by Russian aggression toward Ukraine.

The market downswing in the second half of the year enabled the Fund to purchase many attractively valued stocks of solid businesses with good balance sheets that we expect to emerge stronger. Throughout the period, ARGA maintained strict adherence to our disciplined valuation process. Historically, strict adherence across diverse investing environments leads to periods when portfolio results may widely fluctuate from market indices. Over time, we believe the process optimizes portfolio returns.

The Fund’s value style approach is based on the core belief that investment opportunity results from investor reaction to stress (macro or company). The overreaction reflects investor behavioral biases such as need for certainty. As temporary stress disproportionately impacts valuations, this creates pricing anomalies. Value investors such as ARGA can take advantage of these anomalies to purchase good companies at discounted prices. As conditions recover over time, we expect the stocks to recover.

Temporary weakness mostly impacted certain sectors and companies. Technology, Industrials and Consumer Discretionary sectors were the largest performance detractors. A key contributor to the Fund’s relative results was the absence of highly priced Technology companies, which benefitted from supply shortages. Within the Industrials sector, aerospace, airline, and other travel related companies dragged on renewed COVID concerns. Similar concerns adversely impacted lodging holdings in the Consumer Discretionary sector. Other Consumer Discretionary detractors included a Macau gaming company and China’s largest ecommerce company, both pressured by Chinese regulatory tightening. With solid business models and market advantages, both are expected to recover over time.

 

3


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

The drags on near-term results position the Fund well for future returns. Opportunities for valuation recovery span a range of sectors and geographies. Many are company specific. Areas of undervaluation identified by ARGA Research include:

 

 

Aerospace, airline, lodging and other travel holdings, poised to benefit from eventual travel recovery

 

Select Chinese internet companies, reeling from investor overreaction to China regulatory risk, yet likely to generate strong cash flows

 

Macau gaming companies, where leaders in the growing and highly profitable mass segment should profit as visitations recover

 

European bank holdings, with expected positive profit impacts from cost cuts, rationalization, consolidation and rate normalization

 

More modest opportunities in Energy, where continued capital discipline should mute supply growth, and Technology, where semiconductor stocks are cyclically depressed yet oligopolistic market structures should sustain profitability.

Valuation spreads in international equity markets remain wide. Current spreads between the cheapest and most expensive stocks are far above historical averages. Historically, high spreads have signaled subsequent value outperformance. ARGA Research confirms the Fund should generate strong returns.

Thank you for investing with ARGA.

ARGA Portfolio Construction Team

The material represents the manager’s assessment of the portfolio and market environment at a specific point in time and should not be relied upon by the reader as research or investment advice regarding any stock. Neither this material nor any accompanying oral presentation or remarks by a representative is intended to constitute a recommendation of the Fund or a determination of suitability.

Portfolio holdings are subject to change and should not be considered investment advice or a recommendation to buy securities.

Index performance returns do not reflect any management fees, transaction costs or expenses. Indexes are unmanaged and one cannot invest directly in an index. Past performance does not guarantee future results.

 

4


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

Definition of the Comparative Indices

MSCI Emerging Markets Index captures large and mid-cap representation across 25 Emerging Markets (EM) countries. With 1,422 constituents, the index covers approximately 85% of the free float-adjusted market capitalization in each country.

MSCI Emerging Markets Value Index captures large and mid-cap securities exhibiting overall value style characteristics across 25 Emerging Markets (EM) countries. The value investment style characteristics for index construction are defined using three variables: book value to price, 12-month forward earnings to price and dividend yield.

MSCI ACWI ex U.S. Index captures large and mid-cap representation across 22 of 23 Developed Markets (DM) countries (excluding the US) and 25 Emerging Markets (EM) countries. With 2,336 constituents, the index covers approximately 85% of the global equity opportunity set outside the US.

MSCI ACWI ex U.S. Value Index captures large and mid-cap securities exhibiting overall value style characteristics across 22 Developed and 25 Emerging Markets countries. The value investment style characteristics for index construction are defined using three variables: book value to price, 12-month forward earnings to price and dividend yield.

 

5


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

Comparison of Change in the Value of a $10,000 Investment in the ARGA Emerging Markets Value Fund, Institutional Class Shares, versus the MSCI Emerging Markets Index and MSCI Emerging Markets Value Index.

 

    

AVERAGE ANNUAL TOTAL
RETURN FOR THE

PERIOD ENDED DECEMBER 31,
2021

 
     Cumulative to Inception Date*  

ARGA Emerging Markets Value Fund, Institutional Class Shares

     -8.45

MSCI Emerging Markets Index

     -9.65

MSCI Emerging Markets Value Index

     -6.51

 

LOGO

* The ARGA Emerging Markets Value Fund commenced operations on June 3, 2021.

Fee waivers were in effect previously, if they had not been in effect, performance would have been lower.

The performance data quoted herein represents past performance and the return and value of an investment in the Fund will fluctuate so that, when redeemed, may be worth less than its original cost.

The Fund’s performance assumes the reinvestment of dividends and capital gains. Index returns assume reinvestment of dividends and, unlike a fund’s returns, do not reflect any fees or expenses. If such fees and expenses were included in the index returns, the performance would have been lower.

Please note that one cannot invest directly in an unmanaged index.

There are no assurances that the Fund will meet its stated objectives.

 

6


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

The Fund’s holdings and allocations are subject to change because it is actively managed and should not be considered recommendations to buy individual securities.

Returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

See definition of comparative indices on page 5.

 

7


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

Comparison of Change in the Value of a $10,000 Investment in the ARGA International Value Fund, Institutional Class Shares, versus the MSCI ACWI ex U.S. Index and MSCI ACWI ex U.S. Value Index.

 

    

AVERAGE ANNUAL TOTAL
RETURN FOR THE

PERIOD ENDED DECEMBER 31,
2021

 
     Cumulative to Inception Date*  

ARGA International Value Fund, Institutional Class Shares

     -7.21

MSCI ACWI ex U.S. Index

     -2.36

MSCI ACWI ex U.S. Value Index

     -3.69

 

LOGO

* The ARGA International Value Fund commenced operations on June 3, 2021.

Fee waivers were in effect previously, if they had not been in effect, performance would have been lower.

The performance data quoted herein represents past performance and the return and value of an investment in the Fund will fluctuate so that, when redeemed, may be worth less than its original cost.

The Fund’s performance assumes the reinvestment of dividends and capital gains. Index returns assume reinvestment of dividends and, unlike a fund’s returns, do not reflect any fees or expenses. If such fees and expenses were included in the index returns, the performance would have been lower.

Please note that one cannot invest directly in an unmanaged index.

There are no assurances that the Fund will meet its stated objectives.

 

8


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  
    (Unaudited)  

 

 

 

The Fund’s holdings and allocations are subject to change because it is actively managed and should not be considered recommendations to buy individual securities.

Returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

See definition of comparative indices on page 5.

 

9


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 

 SECTOR WEIGHTINGS (Unaudited)†

 

 

 

LOGO

† Percentages are based on total investments

 

 

 SCHEDULE OF INVESTMENTS

 

 

 COMMON STOCK — 99.5%

 

 

             Shares                  Value    

BRAZIL — 11.8%

 

Banco Bradesco

     1,074,000        $ 3,121,734   

Banco do Brasil

     1,378,500        7,139,986  

JBS

     550,500        3,750,714  

Petroleo Brasileiro ADR

     660,807        7,255,661  

XP, Cl A *

     130        3,739  
     

 

 

 

        21,271,834  
     

 

 

 

CHINA — 22.3%

 

Alibaba Group Holding *

     503,300        7,672,787  

Alibaba Group Holding ADR *

     10,046        1,193,364  

Baidu ADR *

     50,607        7,529,816  

Gree Electric Appliances of Zhuhai, Cl A

             1,245,100        7,230,564  

Hello Group ADR *

     279,980        2,514,220  

Ningbo Huaxiang Electronic, Cl A

     1,101,195        3,735,382  

Shanghai Mechanical and Electrical Industry, Cl A

     1,424,732        3,557,054  

Trip.com Group *

     1,950        47,704  

Trip.com Group ADR *

     149,332        3,676,554  

Weibo ADR *

     90,507        2,803,907  
     

 

 

 

          39,961,352  
     

 

 

 

CZECH REPUBLIC — 1.0%

 

Komercni Banka

     41,262        1,759,974  
     

 

 

 

 

The accompanying notes are an integral part of the financial statements.

 

10


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 SCHEDULE OF INVESTMENTS

 

 

             Shares                  Value    

HONG KONG — 22.3%

 

China Merchants Port Holdings

     2,256,559         $ 4,108,463  

China Resources Power Holdings

     1,088,000        3,640,942  

China Shenhua Energy, Cl H

     1,081,500        2,534,820  

Dongfeng Motor Group, Cl H

     3,692,000        3,067,475  

Galaxy Entertainment Group *

     597,000        3,092,431  

Kunlun Energy

     2,894,000        2,712,441  

Lenovo Group

     2,424,000        2,784,742  

Melco Resorts & Entertainment ADR *

     297,419        3,027,726  

PICC Property & Casualty, Cl H

     6,474,000        5,287,575  

Sands China *

     1,836,000        4,274,968  

Sinopharm Group, Cl H

     1,115,600        2,425,933  

WH Group

             4,963,806        3,112,204  
     

 

 

 

          40,069,720  
     

 

 

 

INDIA — 2.8%

 

REC

     1,480,947        2,662,511  

State Bank of India GDR

     38,968        2,404,325  
     

 

 

 

        5,066,836  
     

 

 

 

INDONESIA — 1.9%

 

Bank Mandiri Persero

     6,747,600        3,332,615  
     

 

 

 

POLAND — 2.6%

 

Powszechna Kasa Oszczednosci Bank Polski *

     24,252        267,930  

Powszechny Zaklad Ubezpieczen

     507,423        4,413,578  
     

 

 

 

        4,681,508  
     

 

 

 

RUSSIA — 3.1%

 

Alrosa PJSC

     3,341,050        5,492,382  
     

 

 

 

SOUTH AFRICA — 3.5%

 

Absa Group

     307,637        2,950,414  

Naspers, Cl N

     21,037        3,269,373  
     

 

 

 

        6,219,787  
     

 

 

 

SOUTH KOREA — 17.7%

 

DB Insurance

     72,656        3,290,346  

Fila Holdings

     82,964        2,501,366  

Hana Financial Group

     70,385        2,484,040  

 

The accompanying notes are an integral part of the financial statements.

 

11


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 SCHEDULE OF INVESTMENTS

 

 

             Shares                  Value    

KB Financial Group

     54,032         $ 2,489,861  

POSCO

     22,006        5,027,622  

Samsung Electronics

     86,420        5,680,857  

SK Hynix

     74,840        8,224,326  

SK Square *

     132        7,373  

WONIK IPS

     56,702        2,010,359  
     

 

 

 

        31,716,150  
     

 

 

 

TAIWAN — 4.0%

 

Catcher Technology

     627,000        3,552,081  

FLEXium Interconnect

     467,000        1,770,720  

Hon Hai Precision Industry

     68,000        255,344  

Zhen Ding Technology Holding

     467,000        1,700,682  
     

 

 

 

        7,278,827  
     

 

 

 

THAILAND — 4.2%

 

Bangkok Bank NVDR

     437,600        1,588,840  

CP ALL

     1,256,300        2,217,709  

Krung Thai Bank

             9,322,000        3,677,798  
     

 

 

 

        7,484,347  
     

 

 

 

UNITED KINGDOM — 0.8%

 

Gazprom PJSC ADR

     164,996        1,524,563  
     

 

 

 

UNITED STATES — 1.5%

 

Cognizant Technology Solutions, Cl A

     30,889        2,740,472  
     

 

 

 

TOTAL COMMON STOCK

(Cost $186,935,110)

        178,600,367  
     

 

 

 

 

 RIGHTS — 0.0%

 

 

     Number of
Rights
     Value

THAILAND — 0.0%

 

CP ALL #

     83,753         
     

 

 

 

TOTAL RIGHTS

(Cost $—)

         
     

 

 

 

TOTAL INVESTMENTS — 99.5%

(Cost $186,935,110)

        $   178,600,367  
     

 

 

 

 

The accompanying notes are an integral part of the financial statements.

 

12


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

  

Percentages are based on Net Assets of $179,438,176.

*

Non-income producing security.

#

Expiration date not available.

ADR — American Depositary Receipt

Cl — Class

GDR — Global Depositary Receipt

NVDR — Non-Voting Depositary Receipt

The following is a list of the inputs used as of December 31, 2021, in valuing the Fund’s investments carried at value:

 

Investments in Securities

   Level 1      Level 2      Level 3      Total  

Common Stock

   $ 122,346,946      $ 56,253,421      $         —      $ 178,600,367  

Rights

                           
  

 

 

    

 

 

    

 

 

    

 

 

 

Total Investments in Securities

   $ 122,346,946      $ 56,253,421      $      $ 178,600,367  
  

 

 

    

 

 

    

 

 

    

 

 

 

For the period ended December 31, 2021, there were no transfers in or out of Level 3.

Amounts designated as “–” are $0.

For more information on valuation inputs, see Note 2 — Significant Accounting Policies in the Notes to Financial Statements.

 

The accompanying notes are an integral part of the financial statements.

 

13


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 

 SECTOR WEIGHTINGS (Unaudited)†

 

 

LOGO

Percentages are based on total investments

 

 

 SCHEDULE OF INVESTMENTS

 

 

 COMMON STOCK — 99.8%

 

 

         Shares              Value    

AUSTRALIA — 0.9%

 

QBE Insurance Group

     3,856        $ 31,732   
     

 

 

 

BERMUDA — 3.0%

 

RenaissanceRe Holdings

     623        105,492  
     

 

 

 

BRAZIL — 3.7%

 

Banco do Brasil

                 10,100        52,313  

Petroleo Brasileiro ADR

     6,912        75,894  
     

 

 

 

        128,207  
     

 

 

 

CANADA — 0.1%

 

Nutrien

     66        4,923  
     

 

 

 

CHINA — 7.1%

 

Alibaba Group Holding *

     1,900        28,966  

Alibaba Group Holding ADR *

     969        115,107  

Baidu ADR *

     690        102,665  
     

 

 

 

                246,738  
     

 

 

 

FINLAND — 0.3%

 

Nokia *

     1,844        11,558  
     

 

 

 

 

The accompanying notes are an integral part of the financial statements.

 

14


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 SCHEDULE OF INVESTMENTS

 

 

         Shares              Value    

FRANCE — 13.9%

 

Accor *

     1,574      $ 50,694  

Airbus *

     832        105,828  

Atos

     1,206          51,047  

AXA

     717        21,254  

Safran

     272        33,151  

Sanofi

     519        52,044  

Societe Generale

     1,570        53,684  

Thales

     390        33,024  

TotalEnergies

     203        10,256  

Vinci

     676        71,101  
     

 

 

 

        482,083  
     

 

 

 

GERMANY — 2.5%

 

Fresenius & KGaA

     1,294        51,857  

MTU Aero Engines

     167        33,916  
     

 

 

 

        85,773  
     

 

 

 

HONG KONG — 6.9%

 

China Shenhua Energy, Cl H

     4,500        10,547  

CK Asset Holdings

     5,500        34,660  

Galaxy Entertainment Group *

     6,000        31,080  

Melco Resorts & Entertainment ADR *

     7,853        79,944  

Sands China *

     33,200        77,303  

WH Group

     10,956        6,869  
     

 

 

 

        240,403  
     

 

 

 

INDONESIA — 1.0%

 

Bank Mandiri Persero

     68,700        33,931  
     

 

 

 

IRELAND — 0.3%

 

AerCap Holdings *

     142        9,290  
     

 

 

 

ITALY — 4.0%

 

Leonardo *

     4,907        34,762  

UniCredit

     6,847        104,129  
     

 

 

 

        138,891  
     

 

 

 

JAPAN — 9.8%

 

Daito Trust Construction

     400        45,830  

Daiwa Securities Group

     6,100        34,376  

 

The accompanying notes are an integral part of the financial statements.

 

15


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 SCHEDULE OF INVESTMENTS

 

 

         Shares              Value    

ITOCHU

     2,300      $ 70,362  

Mitsubishi Electric

     5,300        67,323  

Nomura Holdings

     8,000        34,826  

Seven & i Holdings

     800        35,146  

Subaru

     1,000        17,869  

Taiheiyo Cement

     1,700          33,581  
     

 

 

 

                339,313  
     

 

 

 

NETHERLANDS — 5.3%

 

ABN AMRO Bank

     3,544        51,819  

Aegon

                 12,406        61,697  

Royal Dutch Shell, Cl A

     3,152        68,990  
     

 

 

 

        182,506  
     

 

 

 

SOUTH KOREA — 10.7%

 

POSCO

     320        73,109  

POSCO ADR

     441        25,706  

Samsung Electronics

     1,863        122,465  

Samsung Electronics GDR

     19        31,331  

Shinhan Financial Group ADR

     1,097        33,908  

SK Hynix

     690        75,826  

SK Square *

     66        3,687  

SK Telecom ADR

     185        4,940  
     

 

 

 

                370,972  
     

 

 

 

SWEDEN — 2.2%

 

Boliden

     1,946        75,136  
     

 

 

 

SWITZERLAND — 8.4%

 

Adecco Group

     1,400        71,109  

ams *

     3,660        66,102  

Credit Suisse Group

     3,493        33,706  

Holcim

     1,025        52,211  

UBS Group

     3,945        70,429  
     

 

 

 

        293,557  
     

 

 

 

UNITED KINGDOM — 17.7%

 

Abrdn

     3,868        12,576  

BAE Systems

     4,513        33,487  

Compass Group

     4,956        110,429  

Direct Line Insurance Group

     9,528        35,877  

easyJet *

     6,889        51,694  

 

The accompanying notes are an integral part of the financial statements.

 

16


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
    DECEMBER 31, 2021  

 

 

 

 SCHEDULE OF INVESTMENTS

 

 

         Shares              Value    

GlaxoSmithKline

     2,521      $ 54,662  

HSBC Holdings

     11,586        70,153  

Imperial Brands

     355        7,745  

Lloyds Banking Group

                 51,449        33,190  

NatWest Group

     23,069        70,269  

Pearson

     851        7,043  

Taylor Wimpey

     25,858        61,246  

TechnipFMC *

     5,406        32,003  

Whitbread *

     850        34,357  
     

 

 

 

                614,731  
     

 

 

 

UNITED STATES — 2.0%

 

Capri Holdings *

     1,076        69,843  
     

 

 

 

TOTAL COMMON STOCK

(Cost $3,537,216)

        3,465,079  
     

 

 

 

TOTAL INVESTMENTS — 99.8%

(Cost $3,537,216)

        $         3,465,079  
     

 

 

 

 

  

Percentages are based on Net Assets of $3,473,613.

*

Non-income producing security.

ADR — American Depositary Receipt

Cl — Class

GDR — Global Depositary Receipt

The following is a list of the inputs used as of December 31, 2021, in valuing the Fund’s investments carried at value:

 

Investments in Securities

   Level 1      Level 2          Level 3          Total  

Common Stock

   $ 2,297,607      $ 1,167,472      $         —      $ 3,465,079  
  

 

 

    

 

 

    

 

 

    

 

 

 

Total Investments in Securities

   $ 2,297,607      $ 1,167,472      $      $ 3,465,079  
  

 

 

    

 

 

    

 

 

    

 

 

 

For the period ended December 31, 2021, there were no transfers in or out of Level 3.

For more information on valuation inputs, see Note 2 — Significant Accounting Policies in the Notes to Financial Statements.

 

The accompanying notes are an integral part of the financial statements.

 

17


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 STATEMENTS OF ASSETS AND LIABILITIES

 

 
    ARGA Emerging
Markets Value Fund
  ARGA
International
Value Fund

Assets:

   

Investments, at Value (Cost $186,935,110 and $3,537,216)

    $ 178,600,367         $ 3,465,079    

Foreign Currency, at Value (Cost $74,749 and 556)

    74,749       556  

Cash

    2,183,699       40,247  

Dividend and Interest Receivable

    392,607       6,384  

Reclaim Receivable

    3,076       108  

Deferred Offering Costs (Note 2)

    24,839       24,839  

Receivable for Investment Securities Sold

    408,630       2,669  

Unrealized Gain on Foreign Spot Currency Contracts

    12,639       11  

Receivable for Capital Shares Sold

    294,980        

Reimbursement/Receivable due from Investment Adviser

          27,418  

Other Prepaid Expenses

    2,291       1,207  
 

 

 

 

 

 

 

 

Total Assets

    181,997,877       3,568,518  
 

 

 

 

 

 

 

 

Liabilities:

   

Payable to Investment Adviser

    66,549        

Payable to Administrator

    11,213       6,370  

Chief Compliance Officer Fees Payable

    2,641       51  

Audit Fees Payable

    25,000       25,000  

Payable to Trustees

    32       1  

Payable for Investment Securities Purchased

    1,334,554       31,548  

Payable for Capital Shares Redeemed

    1,036,299        

Other Accrued Expenses and Other Payables

    49,446       3,563  

Legal Fees Payable

    3,637       70  

Accrued Amortization of Offering Costs

    24,839       24,839  

Transfer Agency Fee

    5,491       3,463  
 

 

 

 

 

 

 

 

Total Liabilities

    2,559,701       94,905  
 

 

 

 

 

 

 

 

Net Assets

    $ 179,438,176       $ 3,473,613  
 

 

 

 

 

 

 

 

Net Assets Consist of:

   

Paid-in Capital

    $ 187,888,530       $ 3,543,271  

Total Accumulated Losses

    (8,450,354     (69,658
 

 

 

 

 

 

 

 

Net Assets

    $ 179,438,176       $ 3,473,613  
 

 

 

 

 

 

 

 

Institutional Class Shares:

   

Net Assets

    $ 179,438,176       $ 3,473,613  

Outstanding Shares of beneficial interest (unlimited authorization — no par value)

    19,823,409       376,146  
 

 

 

 

 

 

 

 

Net Asset Value, Offering and Redemption Price Per Share

    $ 9.05       $ 9.23  
 

 

 

 

 

 

 

 

Amounts designated as “—” are $0.

 

The accompanying notes are an integral part of the financial statements.

 

18


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    FOR THE PERIOD ENDED  
    DECEMBER 31, 2021*  

 

 

 

 STATEMENTS OF OPERATIONS

 

 
    ARGA Emerging
Markets Value
Fund
  ARGA
International
Value Fund

Investment Income:

   

Dividends

   $ 2,980,564        $ 27,076    

Interest

    97        

Less: Foreign Taxes Withheld

    (332,969     (3,140
 

 

 

 

 

 

 

 

Total Investment Income

    2,647,692       23,936  
 

 

 

 

 

 

 

 

Expenses:

   

Investment Advisory Fees

    358,810       4,811  

Administration Fees

    55,418       43,562  

Trustees’ Fees

    9,692       3,308  

Chief Compliance Officer Fees

    4,846       538  

Custodian Fees

    37,011       8,892  

Offering Costs

    34,774       34,774  

Legal Fees

    25,134       2,283  

Audit Fees

    25,000       25,000  

Printing Fees

    20,444       556  

Transfer Agent Fees

    18,237       12,481  

Registration and Filing Fees

    6,642       994  

Pricing Fees

    1,128       1,295  

Other Expenses

    16,125       4,291  
 

 

 

 

 

 

 

 

Total Expenses

    613,261       142,785  
 

 

 

 

 

 

 

 

Less:

   

Waiver - Reimbursement from Adviser

    (151,627     (136,772
 

 

 

 

 

 

 

 

Net Expenses

    461,634       6,013  
 

 

 

 

 

 

 

 

Net Investment Income

    2,186,058       17,923  
 

 

 

 

 

 

 

 

Net Realized Gain (Loss) on:

   

Investments

    (95,789     1,027  

Foreign Currency Transactions

    (156,096     1,779  
 

 

 

 

 

 

 

 

Net Realized Gain/(Loss)

    (251,885     2,806  
 

 

 

 

 

 

 

 

Net Change in Unrealized Appreciation (Depreciation) on:

   

Investments

    (8,334,743     (72,137

Foreign Currency Translation

    (1,967     13  
 

 

 

 

 

 

 

 

Net Change in Unrealized Depreciation

    (8,336,710     (72,124
 

 

 

 

 

 

 

 

Net Realized and Unrealized Loss

    (8,588,595     (69,318
 

 

 

 

 

 

 

 

Net Decrease in Net Assets Resulting from Operations

   $ (6,402,537    $     (51,395
 

 

 

 

 

 

 

 

* Commenced operations on June 3, 2021.

 

The accompanying notes are an integral part of the financial statements.

 

19


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
 

 

 

 

 STATEMENTS OF CHANGES IN NET ASSETS

 

    Period
Ended
December 31,
2021*

Operations:

 

Net Investment Income

  $ 2,186,058  

Net Realized Loss on Investments, and Foreign Currency Transactions

    (251,885

Net Change in Unrealized Depreciation on Investments, and Foreign Currency Translations

    (8,336,710
 

 

 

 

Net Decrease in Net Assets Resulting From Operations

    (6,402,537
 

 

 

 

Distributions:

 

Institutional Class Shares

    (2,047,817
 

 

 

 

Total Distributions

    (2,047,817
 

 

 

 

Capital Share Transactions:

 

Institutional Class Shares

 

Issued

    186,918,785  

Reinvestment of Distributions

    2,047,817  

Redeemed

    (1,078,072
 

 

 

 

Net Institutional Class Shares Transactions

    187,888,530  
 

 

 

 

Net Increase in Net Assets From Capital Share Transactions

    187,888,530  
 

 

 

 

Total Increase in Net Assets

    179,438,176  
 

 

 

 

Net Assets:

 

Beginning of Period

     
 

 

 

 

End of Period

  $       179,438,176  
 

 

 

 

Shares Transactions:

 

Institutional Class Shares

 

Issued

    19,715,877  

Reinvestment of Distributions

    226,927  

Redeemed

    (119,395 )   
 

 

 

 

Total Institutional Class Shares Transactions

    19,823,409  
 

 

 

 

Net Increase in Shares Outstanding From Share Transactions

    19,823,409  
 

 

 

 

* Commenced operations on June 3, 2021.

Amounts designated as “—” are $0.

 

The accompanying notes are an integral part of the financial statements.

 

20


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
 

 

 

 

 STATEMENTS OF CHANGES IN NET ASSETS

 

    Period
Ended
December 31,
2021*

Operations:

 

Net Investment Income

  $ 17,923  

Net Realized Gain on Investments, and Foreign Currency Transactions

    2,806  

Net Change in Unrealized Depreciation on Investments, and Foreign Currency Translations

    (72,124 )   
 

 

 

 

Net Decrease in Net Assets Resulting From Operations

    (51,395
 

 

 

 

Distributions:

 

Institutional Class Shares

    (18,263
 

 

 

 

Total Distributions

    (18,263
 

 

 

 

Capital Share Transactions:

 

Institutional Class Shares

 

Issued

    3,525,058  

Reinvestment of Distributions

    18,263  

Redeemed

    (50

Net Institutional Class Shares Transactions

    3,543,271  
 

 

 

 

Net Increase in Net Assets From Capital Share Transactions

    3,543,271  
 

 

 

 

Total Increase in Net Assets

    3,473,613  
 

 

 

 

Net Assets:

 

Beginning of Period

     
 

 

 

 

End of Period

  $         3,473,613  
 

 

 

 

Shares Transactions:

 

Institutional Class Shares

 

Issued

    374,164  

Reinvestment of Distributions

    1,987  

Redeemed

    (5
 

 

 

 

Total Institutional Class Shares Transactions

    376,146  
 

 

 

 

Net Increase in Shares Outstanding From Share Transactions

    376,146  
 

 

 

 

* Commenced operations on June 3, 2021.

Amounts designated as “—” are $0.

 

The accompanying notes are an integral part of the financial statements.

 

21


THE ADVISORS’ INNER CIRCLE FUND III     ARGA EMERGING MARKETS  
    VALUE FUND  
 

 

 

 

 FINANCIAL HIGHLIGHTS

Selected Per Share Data & Ratios

For a Share Outstanding

Throughout the Period

 

     Period
Ended
December 31,
2021(1)
 

Net Asset Value, Beginning of Period

     $10.00       
  

 

 

 

Income (Loss) from Investment Operations:

  

Net Investment Income*

     0.23       

Net Realized and Unrealized Loss

     (1.08)      
  

 

 

 

Total from Investment Operations

     (0.85)      
  

 

 

 

Dividends and Distributions:

  

Net Investment Income

     (0.09)      

Capital Gains

     (0.01)      
  

 

 

 

Total Dividends and Distributions

     (0.10)       
  

 

 

 

Net Asset Value, End of Period

     $9.05        
  

 

 

 

Total Return†

     (8.45)%    
  

 

 

 

Ratios and Supplemental Data

  

Net Assets, End of Period (Thousands)

     $179,438     

Ratio of Net Expenses to Average Net Assets

     0.90%††  

Ratio of Gross Expenses to Average Net Assets

     1.19%††  

Ratio of Net Investment Income to Average Net Assets

     4.24%††  

Portfolio Turnover Rate‡

     17%        

 

*

Per share calculations were performed using average shares for the period.

Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares

††

Annualized

Portfolio turnover is for the period indicated and has not been annualized.

(1)

Commenced operations on June 3, 2021.

 

The accompanying notes are an integral part of the financial statements.

 

22


THE ADVISORS’ INNER CIRCLE FUND III     ARGA INTERNATIONAL  
    VALUE FUND  
 

 

 

 

 FINANCIAL HIGHLIGHTS

Selected Per Share Data & Ratios

For a Share Outstanding

Throughout the Period

 

     Period
Ended
December 31,
2021(1)
 

Net Asset Value, Beginning of Period

     $10.00       
  

 

 

 

Income (Loss) from Investment Operations:

  

Net Investment Income*

     0.12       

Net Realized and Unrealized Loss

     (0.84)      
  

 

 

 

Total from Investment Operations

     (0.72)      
  

 

 

 

Dividends and Distributions:

  

Net Investment Income

     (0.05)      

Capital Gains

     –       
  

 

 

 

Total Dividends and Distributions

     (0.05)      
  

 

 

 

Net Asset Value, End of Period

     $9.23       
  

 

 

 

Total Return†

     (7.21)%   
  

 

 

 

Ratios and Supplemental Data

  

Net Assets, End of Period (Thousands)

     $3,474     

Ratio of Net Expenses to Average Net Assets

     0.75%††  

Ratio of Gross Expenses to Average Net Assets

     17.78%††  

Ratio of Net Investment Income to Average Net Assets

     2.23%††  

Portfolio Turnover Rate‡

     10%        

 

*

Per share calculations were performed using average shares for the period.

Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares

††

Annualized

Portfolio turnover is for the period indicated and has not been annualized.

(1)

Commenced operations on June 3, 2021.

  

Amounts designated as “—” are either not applicable, $0 or have been rounded to $0.

 

The accompanying notes are an integral part of the financial statements.

 

23


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 NOTES TO FINANCIAL STATEMENTS

1. Organization:

The Advisors’ Inner Circle Fund III (the “Trust”) is organized as a Delaware statutory trust under a Declaration of Trust dated December 4, 2013. The Trust is registered under the Investment Company Act of 1940, as amended, as an open-end management investment company with 55 funds. The financial statements herein are those of the ARGA Funds (the “Funds”). The investment objective of each of the ARGA Emerging Markets Value Fund (the “Emerging Markets Value Fund”) and the ARGA International Value Fund (the “International Value Fund”) is to seek to provide long-term capital appreciation. Each of the Emerging Markets Value Fund and the International Value Fund (collectively, the “Funds”) is classified as a non-diversified investment company. ARGA Investment Management, LP (the “Adviser”) serves as each Fund’s investment adviser. Each Fund offers two classes of shares to investors, Investor Shares and Institutional Shares. The financial statements of the remaining funds of the Trust are presented separately. The assets of each fund are segregated, and a shareholder’s interest is limited to the fund in which shares are held. Please refer to a current prospectus for additional information on each share class. Investor Shares of the Funds are currently not available for purchase.

2. Significant Accounting Policies:

The following are significant accounting policies, which are consistently followed in the preparation of the financial statements of the Funds. The Funds are an investment companies that apply the accounting and reporting guidance issued in Topic 946 by the U.S. Financial Accounting Standards Board (“FASB”).

Use of Estimates — The preparation of financial statements, in conformity with U.S. generally accepted accounting principles (“U.S. GAAP”) requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities as of the date of the financial statements and the reported amounts of increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates and such differences could be material.

Security Valuation — Securities listed on a securities exchange, market or automated quotation system for which quotations are readily available (except for securities traded on NASDAQ), including securities traded over the counter, are valued at the last quoted sale price on an exchange or market (foreign or domestic) on which they are traded or, if there is no such reported sale on the valuation date, at the most recent quoted bid price. For securities traded on NASDAQ, the NASDAQ official closing price will be used. The prices for foreign securities are reported in local currency and converted to U.S. dollars using

 

24


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

currency exchange rates. Prices for most securities held in the Funds are provided daily by recognized independent pricing agents. If a security price cannot be obtained from an independent, third-party pricing agent, the Funds seek to obtain a bid price from at least one independent broker.

Securities for which market prices are not “readily available” are valued in accordance with “Fair Value Procedures” established by the Funds’ Board of Trustees (the “Board”). The Funds’ Fair Value Procedures are implemented through a Fair Value Committee (the “Committee”) designated by the Board. Some of the more common reasons that may necessitate that a security be valued using Fair Value Procedures include: the security’s trading has been halted or suspended; the security has been delisted from a national exchange; the security’s primary trading market is temporarily closed at a time when under normal conditions it would be open; the security has not been traded for an extended period of time; the security’s primary pricing source is not able or willing to provide a price; or trading of the security is subject to local government imposed restrictions. When a security is valued in accordance with the Fair Value Procedures, the Committee will determine the value after taking into consideration relevant information reasonably available to the Committee.

In accordance with U.S. GAAP, the Funds disclose fair value of its investments in a hierarchy that prioritizes the inputs to valuation techniques used to measure the fair value. The objective of a fair value measurement is to determine the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date (an exit price).

Accordingly, the fair value hierarchy gives the highest priority to quoted prices (unadjusted) in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The three levels of the fair value hierarchy are described below:

 

   

Level 1 — Unadjusted quoted prices in active markets for identical, unrestricted assets or liabilities that the Funds have the ability to access at the measurement date;

 

   

Level 2 — Other significant observable inputs (includes quoted prices for similar securities, interest rates, prepayment speeds, credit risk, referenced indices, quoted prices in inactive markets, adjusted quoted prices in active markets, adjusted quoted prices on foreign equity securities that were adjusted in accordance with pricing procedures approved by the Board, etc.); and

 

   

Level 3 — Prices, inputs or exotic modeling techniques which are both significant to the fair value measurement and unobservable (supported by little or no market activity).

 

25


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

Investments are classified within the level of the lowest significant input considered in determining fair value. Investments classified within Level 3 whose fair value measurement considers several inputs may include Level 1 or Level 2 inputs as components of the overall fair value measurement.

For the period ended December 31, 2021, there have been no significant changes to the Funds’ fair valuation methodology.

Federal Income Taxes — It is the Funds’ intention to qualify as a regulated investment company for Federal income tax purposes by complying with the appropriate provisions of Subchapter M of the Internal Revenue Code of 1986, as amended. Accordingly, no provision for Federal income taxes has been made in the financial statements.

The Funds evaluate tax positions taken or expected to be taken in the course of preparing the Funds’ tax returns to determine whether it is “more-likely-than-not” (i.e., greater than 50-percent) that each tax position will be sustained upon examination by a taxing authority based on the technical merits of the position. Tax positions not deemed to meet the more-likely-than-not threshold are recorded as a tax benefit or expense in the current period. The Funds did not record any tax provision in the current period. However, management’s conclusions regarding tax positions taken may be subject to review and adjustment at a later date based on factors including, but not limited to, examination by tax authorities (i.e., from commencement of operations, as applicable), on-going analysis of and changes to tax laws, regulations and interpretations thereof.

As of and during the period ended December 31, 2021, the Funds did not have a liability for any unrecognized tax benefits. The Funds recognize interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statements of Operations. During the period, the Funds did not incur any interest or penalties.

Security Transactions and Investment Income — Security transactions are accounted for on trade date. Costs used in determining realized gains and losses on the sale of investment securities are based on the specific identification method. Dividend income and expense are recorded on the ex-dividend date. Dividend income is recorded net of unrecoverable withholding tax. Interest income is recognized on the accrual basis from settlement date. Certain dividends and expenses from foreign securities will be recorded as soon as the Funds are informed of the dividend if such information is obtained subsequent to the ex-dividend date.

Foreign Currency Translation — The books and records of the Funds are maintained in U.S. dollars. Investment securities and other assets and liabilities

 

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    DECEMBER 31, 2021  
 

 

 

 

denominated in a foreign currency are translated into U.S. dollars on the date of valuation. The Funds do not isolate that portion of realized or unrealized gains and losses resulting from changes in the foreign exchange rate from fluctuations arising from changes in the market prices of the securities. These gains and losses are included in net realized and unrealized gains and losses on investments on the Statement of Operations. Net realized and unrealized gains and losses on foreign currency transactions represent net foreign exchange gains or losses from foreign currency exchange contracts, disposition of foreign currencies, currency gains or losses realized between trade and settlement dates on securities transactions and the difference between the amount of the investment income and foreign withholding taxes recorded on the Funds’ books and the U.S. dollar equivalent amounts actually received or paid.

Classes — Class specific expenses are borne by that class of shares. Income, realized and unrealized gains (losses), and non-class specific expenses are allocated to the respective class on basis of relative daily net assets.

Cash — Idle cash may be swept into various time deposit accounts and is classified as cash on the Statements of Assets and Liabilities. The Funds maintain cash in bank deposit accounts which, at times may exceed United States federally insured limits. Amounts invested are available on the same business day.

Expenses — Most expenses of the Trust can be directly attributed to a particular fund. Expenses which cannot be directly attributed to a particular fund are apportioned among the funds of the Trust based on the number of funds and/or relative net assets.

Dividends and Distributions to Shareholders — Each Fund distributes its net investment income and makes distributions of its net realized capital gains, if any, at least annually. If you own Fund shares on a Fund’s record date, you will be entitled to receive the distribution.

Redemption Fees — A redemption fee of 2.00% of the value of the shares sold will be imposed on shares redeemed within 60 days or less after their date of purchase.

Deferred Offering Costs — Offering costs, including costs of printing initial prospectus, legal and registration fees, are amortized over twelve-months from inception of the Fund. During the period ended December 31, 2021, the ARGA Emerging Markets Value Fund and ARGA International Value Fund incurred offering costs of $59,613 and $59,613, respectively. As of December 31, 2021, the ARGA Emerging Markets Value Fund and ARGA International Value Fund have deferred offering costs remaining to be amortized of $24,839 and $24,839, respectively.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

3. Transactions with Affiliates:

Certain officers of the Trust are also employees of SEI Investments Global Funds Services (the “Administrator”), a wholly owned subsidiary of SEI Investments Company, and/or SEI Investments Distribution Co. (the “Distributor”). Such officers are paid no fees by the Trust, other than the Chief Compliance Officer (“CCO”) as described below, for serving as officers of the Trust.

The services provided by the CCO and his staff are paid for by the Trust as incurred. The services include regulatory oversight of the Trust’s Advisors and service providers as required by SEC regulations. The CCO’s services and fees have been approved by and are reviewed by the Board.

4. Administration, Custodian and Transfer Agent Agreements:

The Funds and the Administrator are parties to an Administration Agreement under which the Administrator provides administration services to the Funds. For these services, the Administrator is paid an asset based fee, which will vary depending on the number of share classes and the average daily net assets of the Funds. For the period ended December 31, 2021, ARGA Emerging Markets Value Fund and ARGA International Value Fund each paid $55,418 and $43,562 for these services, respectively.

Brown Brothers Harriman & Co. acts as custodian (the “Custodian”) for the Funds. The Custodian plays no role in determining the investment policies of the Funds or which securities are to be purchased or sold by the Funds. For the period ended December 31, 2021, the ARGA Emerging Markets Value Fund and ARGA International Value Fund each paid $37,011 and $8,892 for these services, respectively.

Atlantic Shareholder Services LLC serves as the transfer agent and dividend disbursing agent for the Funds under a transfer agency agreement with the Trust. For the period ended December 31, 2021, the ARGA Emerging Markets Value Fund and ARGA International Value Fund each paid $18,237 and $12,481 for these services, respectively.

5. Investment Advisory Agreement:

Under the terms of an investment advisory agreement, the Adviser provides investment advisory services to the ARGA Emerging Markets Value Fund and ARGA International Value Fund at a fee, which is calculated daily and paid monthly, at an annual rate of 0.70% and 0.60%, respectively of each Fund’s average daily net assets.

For each Fund, the Adviser has contractually agreed to reduce its fees and/or reimburse expenses to the extent necessary to keep the Funds’ total annual Fund

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

operating expenses (excluding distribution and/or service (12b-1) fees, shareholder servicing fees, interest, taxes, brokerage commissions, and other costs and expenses relating to the securities that are purchased and sold by the Fund, dividend and interest expenses on securities sold short, acquired fund fees and expenses, fees and expenses incurred in connection with tax reclaim recovery services, other expenditures which are capitalized in accordance with generally accepted accounting principles, and non-routine expenses (collectively, “excluded expenses”)) for Investor Shares and Institutional Shares from exceeding certain levels as set forth below until April 30, 2022. Refer to Waiver - Reimbursement from Adviser on the Statement of Operations for fees waived for the period ended December 31, 2021.

Accordingly, the contractual expense limitations for each Fund are as follows:

 

             Contractual Expense Limitations        
Institutional Shares

ARGA Emerging Markets Value Fund

       0.90 %

ARGA International Value Fund

       0.75 %

In addition, the Adviser may receive from a Fund the difference between the total annual Fund operating expenses (not including excluded expenses) and the Fund’s contractual expense limit to recoup all or a portion of its prior fee waivers or expense reimbursements made during the rolling three-year period preceding the date of the recoupment if at any point total annual Fund operating expenses (not including excluded expenses) are below the contractual expense limit (i) at the time of the fee waiver and/or expense reimbursement and (ii) at the time of the recoupment. This agreement may be terminated: (i) by the Board, for any reason at any time; or (ii) by the Adviser, upon ninety (90) days’ prior written notice to the Trust, effective as of the close of business on April 30, 2022.

As of December 31, 2021, fees which were previously waived and/or reimbursed by the Adviser, which may be subject to possible future reimbursement to the Adviser were $151,627 expiring in 2024 and $136,772 expiring in 2024 for ARGA Emerging Markets Value Fund and ARGA International Value Fund, respectively. During the year ended December 31, 2021, there has been no recoupment of previously waived and reimbursed fees.

6. Investment Transactions:

For the period ended December 31, 2021, the purchases and sales of investment securities other than long-term U.S. Government and short-term investments, were as follows:

 

     Purchases   Sales

ARGA Emerging Markets Value Fund

     $                 202,091,324        $                 15,075,659   

ARGA International Value Fund

     3,690,847       158,350  

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

7. Federal Tax Information:

The amount and character of income and capital gain distributions to be paid, if any, are determined in accordance with Federal income tax regulations, which may differ from U.S. GAAP. As a result, net investment income (loss) and net realized gain/(loss) on investment transactions for a reporting period may differ significantly from distributions during the year. The book/tax differences may be temporary or permanent. To the extent these differences are permanent in nature, they are charged or credited to undistributed net investment income (loss), accumulated net realized gain (loss) or paid-in capital as appropriate, in the period that the difference arises.

The permanent differences primarily consist of foreign currency translations and distribution reclassification. There are no permanent differences that are credited or charged to Paid-in Capital and Distributable Earnings as of December 31, 2021.

The tax character of dividends and distributions paid during the period ended December 31, 2021, was as follows:

 

                        Ordinary Income                                   Total                           
ARGA Emerging Markets Value Fund      2021        $                             2,047,817        $                             2,047,817  
ARGA International Value Fund      2021        18,263        18,263  

As of December 31, 2021, the components of distributable earnings on a tax basis were as follows:

 

     ARGA Emerging
Markets Value
Fund
     ARGA
International
Value Fund
 

Undistributed Ordinary Income

     $ 270,149      $ 2,467  

Post-October Losses

     (286,934       

Unrealized Depreciation

     (8,433,566      (72,125

Other Temporary Differences

     (3       
  

 

 

    

 

 

 

Total Accumulated Losses

     $ (8,450,354    $ (69,658
  

 

 

    

 

 

 

Post October losses represent losses realized on investment transactions from November 1, 2021 through December 31, 2021, that, in accordance with Federal income tax regulations, the Funds may defer and treat as having arisen in the following fiscal year.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

The Federal tax cost and aggregate gross unrealized appreciation and depreciation for investments held by Funds at December 31, 2021, were as follows:

 

      Federal Tax Cost      Aggregate
Gross
Unrealized
  Appreciation  
    Aggregate
Gross
Unrealized
  Depreciation  
    Net Unrealized
    Depreciation    
 
ARGA Emerging Markets Value Fund   $  187,019,406     $  6,224,867     $  (14,658,433   $  (8,433,566
ARGA International Value Fund     3,537,216       74,419       (146,544     (72,125

The book/tax difference on investment cost is primarily related to deferred wash sale losses, mark to market on Forward Contracts and investments in passive foreign investment companies.

8. Concentration of Shareholders:

At December 31, 2021, the percentage of total shares outstanding held by shareholders for each Fund, which are comprised of individual shareholders and omnibus accounts that are held on behalf of various individual shareholders was as follows:

 

     No. of

  Shareholders  
   %
      Ownership      

ARGA Emerging Markets Value Fund, Institutional Shares

   2    86%

ARGA International Value Fund, Institutional Shares

   2    100%

In the normal course of business, the Funds enter into contracts that provide general indemnifications. The Funds’ maximum exposure under these arrangements is dependent on future claims that may be made against the Funds and, therefore, cannot be established; however, based on experience, the risk of loss from such claim is considered remote.

9. Concentration of Risks:

As with all mutual funds, there is no guarantee that the Fund will achieve its investment objective. You could lose money by investing in the Fund. A Fund share is not a bank deposit and it is not insured or guaranteed by the FDIC or any government agency.

Equity Risk — The risk that stock prices will fall over short or extended periods of time, sometimes rapidly and unpredictably. The value of equity securities will fluctuate in response to factors affecting a particular company, as well as broader market and economic conditions. Broad movements in financial markets may adversely affect the price of the Fund’s investments, regardless of how well the companies in which the Fund invests perform. Moreover, in the event of a company’s bankruptcy, claims of certain creditors, including bondholders, will have priority over claims of common stock holders such as the Fund.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

Market Risk — The prices of and the income generated by the Fund’s securities may decline in response to, among other things, investor sentiment, general economic and market conditions, regional or global instability, and currency and interest rate fluctuations. In addition, the impact of any epidemic, pandemic or natural disaster, or widespread fear that such events may occur, could negatively affect the global economy, as well as the economies of individual countries, the financial performance of individual companies and sectors, and the markets in general in significant and unforeseen ways. Any such impact could adversely affect the prices and liquidity of the securities and other instruments in which the Fund invests, which in turn could negatively impact the Fund’s performance and cause losses on your investment in the Fund. Market risk may affect a single issuer, an industry, a sector or the equity or bond market as a whole.

Active Management Risk — The Fund is subject to the risk that the Adviser’s judgments about the attractiveness, value, or potential appreciation of the Fund’s investments may prove to be incorrect. If the investments selected and strategies employed by the Fund fail to produce the intended results, the Fund could underperform in comparison to other funds with similar objectives and investment strategies.

Value Style Risk — The Adviser’s value investment style may increase the risks of investing in the Fund. If the Adviser’s assessment of market conditions, or a company’s value or prospects for exceeding earnings expectations is inaccurate, the Fund could suffer losses or produce poor performance relative to other funds. In addition, “value stocks” can continue to be undervalued by the market for long periods of time.

Foreign Investment/Emerging Markets Risk — The risk that non-U.S. securities may be subject to additional risks due to, among other things, political, social and economic developments abroad, currency movements, and different legal, regulatory and tax environments. These additional risks may be heightened with respect to emerging market countries because political turmoil and rapid changes in economic conditions are more likely to occur in these countries. In addition, periodic U.S. Government restrictions on investments in issuers from certain foreign countries may require the Fund to sell such investments at inopportune times, which could result in losses to the Fund.

Geographic Focus Risk — To the extent that it focuses its investments in a particular country or geographic region, the Fund may be more susceptible to economic, political, regulatory or other events or conditions affecting issuers and countries within that country or geographic region. As a result, the Fund may be subject to greater price volatility and risk of loss than a fund holding more geographically diverse investments.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

Sector Focus Risk — Because the Fund may, from time to time, be more heavily invested in particular sectors, the value of its shares may be especially sensitive to factors and economic risks that specifically affect those sectors. As a result, the Fund’s share price may fluctuate more widely than the value of shares of a mutual fund that invests in a broader range of sectors.

Currency Risk — As a result of the Fund’s investments in securities or other investments denominated in, and/or receiving revenues in, foreign currencies, the Fund will be subject to currency risk. Currency risk is the risk that foreign currencies will decline in value relative to the U.S. dollar, resulting in the dollar value of an investment in the Fund being adversely affected. Currency exchange rates may fluctuate in response to, among other things, changes in interest rates, intervention (or failure to intervene) by U.S. or foreign governments, central banks or supranational entities, or by the imposition of currency controls or other political developments in the United States or abroad.

Liquidity Risk — Certain securities may be difficult or impossible to sell at the time and the price that the Fund would like. The Fund may have to accept a lower price to sell a security, sell other securities to raise cash, or give up an investment opportunity, any of which could have a negative effect on Fund management or performance. Liquidity risk may be heightened in the emerging market countries in which the Fund invests, as a result of their markets being less developed.

Depositary Receipts Risk — Depositary receipts, such as ADRs, GDRs and EDRs, are certificates evidencing ownership of shares of a foreign issuer that are issued by depositary banks and generally trade on an established market. Depositary receipts are subject to many of the risks associated with investing directly in foreign securities, including, among other things, political, social and economic developments abroad, currency movements and different legal, regulatory and tax environments.

Preferred Stock Risk — Preferred stocks in which the Fund may invest are sensitive to interest rate changes, and are also subject to equity risk, which is the risk that stock prices will fall over short or extended periods of time. The rights of preferred stocks on the distribution of a company’s assets in the event of a liquidation are generally subordinate to the rights associated with a company’s debt securities.

Private Placements Risk — Investment in privately placed securities may be less liquid than in publicly traded securities. Although these securities may be resold in privately negotiated transactions, the prices realized from these sales could be less than those originally paid by the Fund or less than what may be considered the fair value of such securities. Furthermore, companies whose securities are not publicly traded may not be subject to the disclosure and other investor protection requirements that might be applicable if their securities were publicly traded.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

Participation Notes Risk — The return on a P-Note is linked to the performance of the issuers of the underlying securities. The performance of P-Notes will not replicate exactly the performance of the issuers that they seek to replicate due to transaction costs and other expenses. P-Notes are subject to counterparty risk since the notes constitute general unsecured contractual obligations of the financial institutions issuing the notes, and the Fund is relying on the creditworthiness of such institutions and has no rights under the notes against the issuers of the underlying securities. In addition, P-Notes are subject to liquidity risk, which is described elsewhere in this section.

REITs Risk — REITs are pooled investment vehicles that own, and usually operate, income-producing real estate. REITs are susceptible to the risks associated with direct ownership of real estate, such as the following: declines in property values; increases in property taxes, operating expenses, interest rates or competition; overbuilding; zoning changes; and losses from casualty or condemnation. REITs typically incur fees that are separate from those of the Fund. Accordingly, the Fund’s investments in REITs will result in the layering of expenses such that shareholders will indirectly bear a proportionate share of the REITs’ operating expenses, in addition to paying Fund expenses. REIT operating expenses are not reflected in the fee table and example in this prospectus.

ETFs Risk — ETFs are pooled investment vehicles, such as registered investment companies and grantor trusts, whose shares are listed and traded on U.S. and non-U.S. stock exchanges or otherwise traded in the over-the-counter market. To the extent that the Fund invests in ETFs, the Fund will be subject to substantially the same risks as those associated with the direct ownership of the securities in which the ETF invests, and the value of the Fund’s investment will fluctuate in response to the performance of the ETF’s holdings. ETFs typically incur fees that are separate from those of the Fund. Accordingly, the Fund’s investments in ETFs will result in the layering of expenses such that shareholders will indirectly bear a proportionate share of the ETFs’ operating expenses, in addition to paying Fund expenses.

Stock Connect Investing Risk — Trading through Stock Connect is subject to a number of restrictions that may affect the Fund’s investments and returns, including a daily quota that limits the maximum net purchases under Stock Connect each day. In addition, investments made through Stock Connect are subject to relatively untested trading, clearance and settlement procedures. Moreover, A-Shares purchased through Stock Connect generally may only be sold or otherwise transferred through Stock Connect. The Fund’s investments in A-Shares purchased through Stock Connect are generally subject to Chinese securities regulations and listing rules. While overseas investors currently are exempt from paying capital gains or value added taxes on income and gains from investments in A-Shares purchased through Stock Connect, these tax rules could be changed, which could result in

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

unexpected tax liabilities for the Fund. Stock Connect operates only on days when both the China and Hong Kong markets are open for trading and when banks in both markets are open on the corresponding settlement days. Therefore, the Fund may be subject to the risk of price fluctuations of A-Shares when Stock Connect is not trading.

New Fund Risk — Because the Fund is new, investors in the Fund bear the risk that the Fund may not be successful in implementing its investment strategy, may not employ a successful investment strategy, or may fail to attract sufficient assets under management to realize economies of scale, any of which could result in the Fund being liquidated at any time without shareholder approval and at a time that may not be favorable for all shareholders. Such liquidation could have negative tax consequences for shareholders and will cause shareholders to incur expenses of liquidation.

10. Subsequent Events:

The Funds have evaluated the need for additional disclosures and/or adjustments resulting from subsequent events through the date the financial statements were issued. Based on this evaluation, no additional disclosures and/or adjustments, other than that listed below, were required to the financial statements as of December 31, 2021.

On September 7, 2021, Brown Brothers Harriman & Co. (“BBH”), the Fund’s custodian, announced that it had entered into an agreement with State Street Bank and Trust Company (“State Street”) to sell BBH’s Investor Services business to State Street (the “Transaction”). The Transaction is subject to certain closing conditions, including regulatory and customary approvals, and it is expected to be consummated in the first quarter of 2022 (the “Closing Date”). Consequently, as a result of the Transaction, it is expected that State Street will replace BBH as the Fund’s custodian effective as of the Closing Date.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
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 REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

 

To the Board of Trustees of The Advisors’ Inner Circle Fund III and Shareholders of ARGA Emerging Markets Value Fund and ARGA International Value Fund

Opinion on the Financial Statements

We have audited the accompanying statements of assets and liabilities, of ARGA Emerging Markets Value Fund and ARGA International Value Fund (collectively referred to as the “Funds”) (two of the series constituting The Advisors’ Inner Circle Fund III (the “Trust”)), including the schedules of investments, as of December 31, 2021, and the related statements of operations, changes in net assets and the financial highlights for each of the periods indicated in the table below and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Funds (two of the series constituting The Advisors’ Inner Circle Fund III) at December 31, 2021, the results of their operations, the changes in their net assets and the financial highlights for each of the periods indicated in the table below, in conformity with U.S. generally accepted accounting principles.

 

Individual fund constituting

The Advisors’ Inner Circle Fund III

  Statements of operations   Statements of changes in net assets   Financial highlights

ARGA Emerging Markets Value Fund

 

ARGA International Value Fund

  For the period from June 3, 2021 (commencement of operations) through December 31, 2021   For the period from June 3, 2021 (commencement of operations) through December 31, 2021   For the period from June 3, 2021 (commencement of operations) through December 31, 2021

Basis for Opinion

These financial statements are the responsibility of the Trust’s management. Our responsibility is to express an opinion on the Funds’ financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Trust in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. The Trust is not required to have, nor were we engaged to perform, an audit of the Trust’s internal control over financial reporting. As part of our audits, we are required to obtain an understanding of internal control over financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the Trust’s internal control over financial reporting. Accordingly, we express no such opinion.

 

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    DECEMBER 31, 2021  
 

 

 

 

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of December 31, 2021, by correspondence with the custodian and brokers or by other appropriate auditing procedures where replies from brokers were not received. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

 

LOGO

We have served as the auditor of one or more ARGA Investment Management, LP investment companies since 2021.

Philadelphia, Pennsylvania

February 28, 2022

 

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 TRUSTEES AND OFFICERS OF THE ADVISORS’ INNER CIRCLE FUND III (Unaudited)

 

 

Set forth below are the names, years of birth, positions with the Trust, length of term of office, and the principal occupations for the last five years of each of the persons currently serving as Trustees and Officers of the Trust. Unless otherwise noted, the business address of each Trustee is SEI Investments Company, 1 Freedom Valley Drive, Oaks Pennsylvania 19456. Trustees who are deemed not to be “interested persons” of the Trust are referred to as “Independent Trustees.” Mr. Doran is a Trustee who may be

 

Name and Year of Birth

 

  

Position with Trust and length
of Time Served1

 

 

Principal Occupation in the Past Five Years2

 

INTERESTED TRUSTEES3,4

   

William M. Doran

(Born: 1940)

   Chairman of
Board of Trustees
(Since 2014)
 

Self-Employed Consultant since 2003. Partner at Morgan, Lewis & Bockius LLP (law firm) from 1976 to 2003. Counsel to the Trust, SEI Investments, SIMC, the Administrator and the Distributor. Secretary of SEI Investments since 1978.

 

 

 

 

 

INDEPENDENT TRUSTEES2

   

Jon C. Hunt

(Born: 1951)

   Trustee and Lead
Independent Trustee
(Since 2014)
 

Retired since 2013. Consultant to Management, Convergent Capital Management, LLC (“CCM”) from 2012 to 2013. Managing Director and Chief Operating Officer, CCM from 1998 to 2012..

 

Thomas P. Lemke

(Born: 1954)

   Trustee
(Since 2014)
 

Retired since 2013. Executive Vice President and General Counsel, Legg Mason, Inc. from 2005 to 2013.

 

 

 

1 Each Trustee shall hold office during the lifetime of this Trust until the election and qualification of his or her successor, or until he or she sooner dies, resigns, or is removed in accordance with the Trust’s Declaration of Trust.

2 Denotes Trustees who may be deemed to be “interested” persons of the Fund as that term is defined in the 1940 Act by virtue of their affiliation with the Distributor and/or its affiliates.

3 Trustees oversee 55 funds in The Advisors’ Inner Circle Fund III.

 

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THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
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deemed to be “interested” persons of the Trust as that term is defined in the 1940 Act by virtue of their affiliation with the Trust’s Distributor. The Trust’s Statement of Additional Information (“SAI”) includes additional information about the Trustees and Officers. The SAI may be obtained without charge by calling 1-844-523-8637. The following chart lists Trustees and Officers as of October 31, 2019.

 

 

Other Directorships

Held in the Past Five Years

 

    

    

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, SEI Daily Income Trust, SEI Institutional International Trust, SEI Institutional Investments Trust, SEI Institutional Managed Trust, SEI Asset Allocation Trust, SEI Tax Exempt Trust, Adviser Managed Trust, New Covenant Funds, SEI Insurance Products Trust and SEI Catholic Values Trust. Director of SEI Investments, SEI Investments (Europe), Limited, SEI Investments—Global Funds Services, Limited, SEI Investments Global, Limited, SEI Investments (Asia), Limited, SEI Global Nominee Ltd., SEI Investments – Unit Trust Management (UK) Limited and SEI Investments Co. Director of the Distributor.

 

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016.

Trustee of SEI Liquid Asset Trust to 2016. Trustee of Winton Series Trust to 2017. Trustee of The Advisors’ Inner Circle Fund, The Advisors’ Inner Circle Fund II, Bishop Street Funds, The KP Funds and Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

 

Current Directorships: Trustee of City National Rochdale Funds, Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund and Delaware Wilshire Private Markets Tender Fund. Director of Chiron Capital Allocation Fund Ltd.

 

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Member of Independent Committee of Nuveen Commodities Asset Management to 2016. Trustee of Winton Series Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, JP Morgan Active Exchange-Traded Funds (33 Portfolios) and Symmetry Panoramic Trust (8 Portfolios). Director of Chiron Capital Allocation Fund Ltd.

 

Former Directorships: Trustee of Munder Funds to 2014. Trustee of Victory Funds to 2015. Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of Winton Series Trust and AXA Premier VIP Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

4 Directorships of Companies required to report to the Securities and Exchange Commission under the Securities Exchange act of 1934 (i.e., “public companies) or other investment companies under the 1940 Act.

 

39


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 TRUSTEES AND OFFICERS OF THE ADVISORS’ INNER CIRCLE FUND III (Unaudited)

 

 

 

 

 

Name and
Year of Birth

 

  

Position with the Trust and Length
of Time Served1

 

 

Principal Occupation During the Past Five Years2

 

INDEPENDENT TRUSTEES (continued)3

   

Nichelle Maynard-Elliott

(Born: 1968)

   Trustee
(since 2021)
 

Independent Director since 2018. Executive Director, M&A at Praxair Inc. from 2011-2019.

 

Jay C. Nadel

(Born: 1958)

   Trustee
(Since 2016)
 

Self-Employed Consultant since 2004. Executive Vice President, Bank of New York Broker Dealer from 2002 to 2004. Partner/Managing Director, Weiss Peck & Greer/Robeco from 1986 to 2001.

 

Randall S. Yanker

(Born: 1960)

   Trustee
(Since 2014)
 

Co-Founder and Senior Partner, Alternative Asset Managers, L.P. since 2004.

 

OFFICERS

   

Michael Beattie

(Born: 1965)

   President
(Since 2014)
 

Director of Client Service, SEI Investments Company, since 2004.

 

James Bernstein

(Born: 1962)

   Vice President
(since 2017)
 

Attorney, SEI Investments, since 2017.

 

     Secretary
(since 2020)
 

Prior Positions: Self-employed consultant, 2017. Associate General Counsel & Vice President, Nationwide Funds Group and Nationwide Mutual Insurance Company, from 2002 to 2016. Assistant General Counsel & Vice President, Market Street Funds and Provident Mutual Insurance Company, from 1999 to 2002.

 

John Bourgeois

(Born: 1973)

   Assistant Treasurer
(since 2017)
 

Fund Accounting Manager, SEI Investments, since 2000.

 

1 Each Trustee shall hold office during the lifetime of this Trust until the election and qualification of his or her successor, or until he or she sooner dies, resigns, or is removed in accordance with the Trust’s Declaration of Trust.

2 Directorships of Companies required to report to the Securities and Exchange Commission under the Securities Exchange act of 1934 (i.e., “public companies) or other investment companies under the 1940 Act.

 

40


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 

 

 

Other Directorships
Held in the Past Five Years

 

 

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund. Director of Chiron Capital Allocation Fund Ltd. Director of Element Solutions Inc., Director of Xerox Holdings Corporation, and Director Nominee for Lucid Group, Inc.

 

Current Directorships: Chairman of the Board of Trustees of City National Rochdale Funds. Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund and Delaware Wilshire Private Markets Tender Fund. Director of Chiron Capital Allocation Fund Ltd.

 

Former Directorships: Trustee of Winton Series Trust to 2017. Director of Lapolla Industries, Inc. to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund and Delaware Wilshire Private Markets Tender Fund. Independent Non-Executive Director of HFA Holdings Limited. Director of Chiron Capital Allocation Fund Ltd.

 

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of Winton Series Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

 

None.

 

None.

 

    

    

    

    

    

    

 

None.

 

3 Trustees oversee 55 funds in The Advisors’ Inner Circle Fund III.

 

41


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 TRUSTEES AND OFFICERS OF THE ADVISORS’ INNER CIRCLE FUND III (Unaudited)

 

 

 

 

 

Name and Year of Birth

 

  

Position with Trust and Length of
Time Served

 

 

Principal Occupation During the Past Five Years

 

OFFICERS (continued)

   

Russell Emery

(Born: 1962)

  

Chief Compliance Officer

(since 2014)

 

Chief Compliance Officer of SEI Structured Credit Fund, LP since 2007. Chief Compliance Officer of The Advisors’ Inner Circle Fund, The Advisors’ Inner Circle Fund II, Bishop Street Funds, Frost Family of Funds, Catholic Responsible Investments Funds, Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, SEI Institutional Managed Trust, SEI Asset Allocation Trust, SEI Institutional International Trust, SEI Institutional Investments Trust, SEI Daily Income Trust, SEI Tax Exempt Trust, Adviser Managed Trust, New Covenant Funds, SEI Insurance Products Trust and SEI Catholic Values Trust. Chief Compliance Officer of O’Connor EQUUS (closed-end investment company) to 2016. Chief Compliance Officer of SEI Liquid Asset Trust to 2016. Chief Compliance Officer of Winton Series Trust to 2017. Chief Compliance Officer of Winton Diversified Opportunities Fund (closed-end investment company) to 2018. Chief Compliance Officer of The KP Funds to 2021.

 

Eric C. Griffith

(Born: 1969)

   Vice President and Assistant Secretary (since 2020)  

Counsel at SEI Investments since 2019. Vice President and Assistant General Counsel, JPMorgan Chase & Co., from 2012 to 2018.

 

Matthew M. Maher

(Born: 1975)

   Vice President and Assistant Secretary (since 2018)  

Counsel at SEI Investments since 2018. Attorney, Blank Rome LLP, from 2015 to 2018. Assistant Counsel & Vice President, Bank of New York Mellon, from 2013 to 2014. Attorney, Dilworth Paxson LLP, from 2006 to 2013.

 

Andrew Metzger

(Born: 1980)

   Treasurer, Controller and Chief Financial Officer
(since 2021)
 

Director of Fund Accounting, SEI Investments, since 2020. Senior Director, Embark, from 2019 to 2020. Senior Manager, PricewaterhouseCoopers LLP, from 2002 to 2019.

 

Robert Morrow

(Born: 1968)

 

   Vice President
(since 2017)
 

Account Manager, SEI Investments, since 2007.

 

 

42


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 

 

 

Other Directorships

Held in the Past Five Years

 

    

    

None.

 

None.

 

None.

 

None.

 

None.

 

 

43


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 DISCLOSURE OF FUND EXPENSES (Unaudited)

 

 

All mutual funds have operating expenses. As a shareholder of a mutual fund, your investment is affected by these ongoing costs, which include (among others) costs for Fund management, administrative services, and shareholder reports like this one. It is important for you to understand the impact of these costs on your investment returns.

Operating expenses such as these are deducted from the mutual fund’s gross income and directly reduce your final investment return. These expenses are expressed as a percentage of the mutual fund’s average net assets; this percentage is known as the mutual fund’s expense ratio.

The following examples use the expense ratio and are intended to help you understand the ongoing costs (in dollars) of investing in your Fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period from July 1, 2021 to December 31, 2021.

The table on the next page illustrates your Fund’s costs in two ways:

Actual Fund Return. This section helps you to estimate the actual expenses after fee waivers that your Fund incurred over the period. The “Expenses Paid During Period” column shows the actual dollar expense cost incurred by a $1,000 investment in the Fund, and the “Ending Account Value” number is derived from deducting that expense cost from the Fund’s gross investment return.

You can use this information, together with the actual amount you invested in the Fund, to estimate the expenses you paid over that period. Simply divide your ending starting account value by $1,000 to arrive at a ratio (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply that ratio by the number shown for your Fund under “Expenses Paid During Period.”

Hypothetical 5% Return. This section helps you compare your Fund’s costs with those of other mutual funds. It assumes that the Fund had an annual 5% return before expenses during the year, but that the expense ratio (Column 3) for the period is unchanged. This example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to make this 5% calculation. You can assess your Fund’s comparative cost by comparing the hypothetical result for your Fund in the “Expenses Paid During Period” column with those that appear in the same charts in the shareholder reports for other mutual funds.

 

44


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 DISCLOSURE OF FUND EXPENSES (Unaudited)

 

 

Note: Because the return is set at 5% for comparison purposes — NOT your Fund’s actual return — the account values shown may not apply to your specific investment.

 

      Beginning
Account
Value
7/01/21
     Ending
Account
Value
12/31/21
     Annualized
Expense
Ratios
    Expenses
Paid During
Period*
 

ARGA Emerging Markets Value Fund - Institutional Class Shares

 

Actual Fund Return

     $1,000.00        $928.50        0.90     $4.38  

Hypothetical 5% Return

     1,000.00        1,020.67        0.90       4.58  

ARGA International Value Fund - Institutional Class Shares

 

Actual Fund Return

     $1,000.00        $968.60        0.75     $3.72  

Hypothetical 5% Return

     1,000.00        1,021.42        0.75       3.82  

*   Expenses are equal to the Fund’s annualized expense ratio, multiplied by the average account value over the period, multiplied by 184/365 (to reflect the one-half period shown).

 

45


THE ADVISORS’ INNER CIRCLE FUND III     ARGA FUNDS  
    DECEMBER 31, 2021  
 

 

 

 

 Notice to Shareholders (Unaudited)

 

 

For shareholders that do not have a December 31, 2021 tax year end, this notice is for informational purposes only. For shareholders with a December 31, 2021 tax year end, please consult your tax advisor as to the pertinence of this notice. For the fiscal year ended December 31, 2021, the Fund is designating the following items with regard to distributions paid during the year.

 

Long-Term Capital
Gain Distributions

  Ordinary
Income
Distributions
  Total
Distributions
  Qualifying For
Corporate
Dividend
Received
Deduction (1)
    Qualifying
Dividend
Income (2)
    U.S.
Government
Interest (3)
    Interest
Related
Dividends (4)
    Short-Term
Capital Gain
Dividends (5)
 

ARGA Emerging Markets Value Fund

         
            0.00%   100.00%   100.00%     0.37%       100.00%       0.00%       0.00%       100.00%  

ARGA International Value Fund

         
            0.00%   100.00%   100.00%     0.00%       78.08%       0.00%       0.00%       100.00%  

The Funds intend to pass through foreign tax credit to shareholders. For the fiscal year ended December 31, 2021, the amount of foreign source income and foreign tax credit are as follows:

 

Fund    Foreign Source Income      Foreign Tax Credit Pass Through  

ARGA Emerging Markets Value Fund

   $ 2,502,164      $ 294,065  

ARGA International Value Fund

     10,536        3,047  

 

  1.

Qualifying dividends represent dividends which qualify for the corporate dividends received deduction and is reflected as a percentage of ordinary Income distributions (the total of short term capital gain and net investment income distributions).

 

  2.

The percentage in this column represents the amount of “Qualifying Dividend Income” as created by the Jobs and Growth Tax Relief Reconciliation Act of 2003 and is reflected as a percentage of ordinary income distributions (the total of short term capital gain and net investment income distributions). It is the intention of each of the aforementioned funds to designate the maximum amount permitted by law.

 

  3.

“U.S. Government Interest” represents the amount of interest that was derived from direct U.S. Government obligations and distributed during the fiscal year. This amount is reflected as a percentage of ordinary income. Generally, interest from direct U.S. Government obligations is exempt from state income tax. However, for shareholders who are residents of California, Connecticut and New York, the statutory threshold requirements were not satisfied to permit exemption of these amounts from state income.

 

  4.

The percentage in this column represents the amount of “Interest Related Dividends” and is reflected as a percentage of ordinary income distribution. Interest related dividends are exempt from U.S. withholding tax when paid to foreign investors.

 

  5.

The percentage in this column represents the amount of “Short Term Capital Gain Dividends” and is reflected as a percentage of short term capital gain distribution that is exempt from U.S. withholding tax when paid to foreign investors.

The information reported herein may differ from the information and distributions taxable to the shareholder for the calendar year ending December 31, 2021. Complete information will be computed and reported with your 2021 Form 1099-DIV.

 

46


ARGA Funds

P.O. Box 588

Portland, ME 04112

1- 866-234-2742

Investment Adviser:

ARGA Investment Management, LP

1010 Washington Blvd, 6th Floor

Stamford, CT 06901

Administrator:

SEI Investments Global Funds Services

One Freedom Valley Drive

Oaks, PA 19456

Distributor:

SEI Investments Distribution Co.

One Freedom Valley Drive

Oaks, PA 19456

Legal Counsel:

Morgan, Lewis & Bockius LLP

1701 Market Street

Philadelphia, PA 19103

Independent Registered Public Accounting Firm:

Ernst & Young LLP

One Commerce Square

2005 Market Street, Suite 700

Philadelphia, PA 19103

This information must be preceded or accompanied by a current prospectus for the Funds described.

ARG-AR-001-0100


Item 2.

Code of Ethics.

The Registrant (also referred to as the “Trust”) has adopted a code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, controller or principal accounting officer, and any person who performs a similar function. There have been no amendments to or waivers granted to this code of ethics during the period covered by this report.

 

Item 3.

Audit Committee Financial Expert.

(a)(1) The Registrant’s board of trustees has determined that the Registrant has at least one audit committee financial expert serving on the audit committee.

(a)(2) The Registrant’s audit committee financial experts are Thomas P. Lemke and Jay Nadel, and each of Mr. Lemke and Mr. Nadel is “independent” as that term is defined in Form N-CSR Item 3 (a)(2).

 

Item 4.

Principal Accountant Fees and Services.

Fees billed by PricewaterhouseCoopers LLP (“PwC”) relate to The Advisors’ Inner Circle Fund III (the “Trust”).

PwC billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

 

     FYE December 31, 2021      FYE December 31, 2020  
          All fees and
services to
the Trust
that were
pre-approved
     All fees and
services to
service
affiliates
that were
pre-approved
     All other
fees and
services to
service
affiliates
that did not
require
pre-approval
     All fees and
services to
the Trust
that were
pre-approved
     All fees and
services to
service
affiliates
that were
pre-approved
     All other
fees and
services to
service
affiliates
that did not
require
pre-approval
 
(a)    Audit Fees(1)    $ 704,515        None      $ 11,990      $ 581,815        None      $ 607,218  
(b)    Audit-Related Fees    $ 4,000        None        None        None        None        None  
(c)    Tax Fees(2)      None        None      $ 90,000        None        None      $ 505,050  
(d)    All Other Fees      None        None      $ 1,473        None        None      $ 15,941  


Fees billed by BBD LLP (“BBD”) relate to the Trust.

BBD billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

 

     FYE December 31, 2021      FYE December 31, 2020  
          All fees and
services to
the Trust
that were
pre-approved
     All fees and
services to
service
affiliates
that were
pre-approved
     All other
fees and
services to
service
affiliates
that did not
require
pre-approval
     All fees and
services to
the Trust
that were
pre-approved
     All fees and
services to
service
affiliates
that were
pre-approved
     All other
fees and
services to
service
affiliates
that did not
require
pre-approval
 

(a)

   Audit Fees(1)    $ 87,000        None        None      $ 81,625        None        None  

(b)

   Audit-Related Fees      None        None        None        None        None        None  

(c)

   Tax Fees      None        None        None        None        None        None  

(d)

   All Other Fees      None        None        None        None        None        None  

Fees billed by Ernst & Young LLP (“E&Y”) relate to the Trust.

E&Y billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

 

     FYE December 31, 2021      FYE December 31, 2020  
          All fees and
services to
the Trust
that were
pre-approved
     All fees and
services to
service
affiliates
that were
pre-approved
     All other
fees and
services to
service
affiliates
that did not
require
pre-approval
     All fees and
services to
the Trust
that were
pre-approved
     All fees and
services to
service
affiliates
that were
pre-approved
     All other
fees and
services to
service
affiliates
that did not
require
pre-approval
 
(a)    Audit Fees(1)    $ 51,220        None        None        N/A        N/A        N/A  
(b)    Audit-Related Fees      None        None        None        N/A        N/A        N/A  
(c)    Tax Fees      None        None        None        N/A        N/A        N/A  
(d)    All Other Fees      None        None        None        N/A        N/A        N/A  


Notes:

  (1)

Audit fees include amounts related to the audit of the Trust’s annual financial statements and services normally provided by the accountant in connection with statutory and regulatory filings.

 

  (2)

Tax return preparation fees for affiliates of the Funds.

(e)(1) The Trust’s Audit Committee has adopted and the Board of Trustees has ratified an Audit and Non-Audit Services Pre-Approval Policy (the “Policy”), which sets forth the procedures and the conditions pursuant to which services proposed to be performed by the independent auditor of the Funds may be pre-approved.

The Policy provides that all requests or applications for proposed services to be provided by the independent auditor must be submitted to the Registrant’s Chief Financial Officer (“CFO”) and must include a detailed description of the services proposed to be rendered. The CFO will determine whether such services:

(1) require specific pre-approval;

(2) are included within the list of services that have received the general pre-approval of the Audit Committee pursuant to the Policy; or

(3) have been previously pre-approved in connection with the independent auditor’s annual engagement letter for the applicable year or otherwise. In any instance where services require pre-approval, the Audit Committee will consider whether such services are consistent with SEC’s rules and whether the provision of such services would impair the auditor’s independence.

Requests or applications to provide services that require specific pre-approval by the Audit Committee will be submitted to the Audit Committee by the CFO. The Audit Committee will be informed by the CFO on a quarterly basis of all services rendered by the independent auditor. The Audit Committee has delegated specific pre-approval authority to either the Audit Committee Chair or financial expert, provided that the estimated fee for any such proposed pre-approved service does not exceed $100,000 and any pre-approval decisions are reported to the Audit Committee at its next regularly-scheduled meeting.

Services that have received the general pre-approval of the Audit Committee are identified and described in the Policy. In addition, the Policy sets forth a maximum fee per engagement with respect to each identified service that has received general pre-approval.

All services to be provided by the independent auditor shall be provided pursuant to a signed written engagement letter with the Registrant, the investment adviser, or applicable control affiliate (except that matters as to which an engagement letter would be impractical because of timing issues or because the matter is small may not be the subject of an engagement letter) that sets forth both the services to be provided by the independent auditor and the total fees to be paid to the independent auditor for those services.

In addition, the Audit Committee has determined to take additional measures on an annual basis to meet the Audit Committee’s responsibility to oversee the work of the independent auditor and to assure the auditor’s independence from the Registrant, such as (a) reviewing a formal written statement from the independent auditor delineating all relationships between the independent auditor and the Registrant, and (b) discussing with the independent auditor the independent auditor’s methods and procedures for ensuring independence.


(e)(2) Percentage of fees billed applicable to non-audit services pursuant to (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, waiver of pre-approval requirement were as follows (PwC):

 

     FYE
December 31,
2021
     FYE
December 31,
2020
 

Audit-Related Fees

     None        None  

Tax Fees

     None        None  

All Other Fees

     None        None  

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, waiver of pre-approval requirement were as follows (BBD):

 

     FYE
December 31,
2021
     FYE
December 31,
2020
 

Audit-Related Fees

     None        None  

Tax Fees

     None        None  

All Other Fees

     None        None  

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to (c)(7)(i)(C) of Rule 2-01 of Regulation S-X, waiver of pre-approval requirement were as follows (E&Y):

 

     FYE
December 31,
2021
     FYE
December 31,
2020
 

Audit-Related Fees

     None        N/A  

Tax Fees

     None        N/A  

All Other Fees

     None        N/A  

(f) Not applicable.

(g) The aggregate non-audit fees and services billed by PwC for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal-years-ended December 31st were $91,473 and $520,991 for 2021 and 2020, respectively.

(g) The aggregate non-audit fees and services billed by BBD for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal-years-ended December 31st were $0 and $0 for 2021 and 2020, respectively.


(g) The aggregate non-audit fees and services billed by EY for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal-years-ended December 31st were $0 and $0 for 2021 and 2020, respectively.

(h) During the past fiscal year, all non-audit services provided by the Registrant’s principal accountant to either the Registrant’s investment adviser or to any entity controlling, controlled by, or under common control with the Registrant’s investment adviser that provides ongoing services to the Registrant were pre-approved by the Audit Committee of Registrant’s Board of Trustees. Included in the Audit Committee’s pre-approval of these non-audit service were the review and consideration as to whether the provision of these non-audit services is compatible with maintaining the principal accountant’s independence.

 

Item 5.

Audit Committee of Listed Registrants.

Not applicable to open-end management investment companies.

 

Item 6.

Schedule of Investments.

Schedule of Investments is included as part of the Report to Shareholders filed under Item 1 of this form.

 

Item 7.

Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

 

Item 8.

Portfolio Managers of Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

 

Item 9.

Purchases of Equity Securities by Closed-End Management Company and Affiliated Purchasers.

Not applicable to open-end management investment companies.

 

Item 10.

Submission of Matters to a Vote of Security Holders.

There have been no changes to the procedures by which shareholders may recommend nominees to the Registrant’s Board of Trustees during the period covered by this report.

 

Item 11.

Controls and Procedures.

(a) The Registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the Registrant’s disclosure controls and procedures, as defined in Rule 30a-3(c) under the Act (17 CFR § 270.30a-3(c)), as of a date within 90 days of the filing date of the report, are effective based on the evaluation of these controls and procedures required by Rule 30a-3(b) under the Act (17 CFR § 270.30a-3(b)) and Rule 13a-15(b) or Rule 15d-15(b) under the Exchange Act, as amended (17 CFR § 240.13a-15(b) or § 240.15d-15(b)).


(b) There has been no change in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the Act (17 CFR § 270.3a-3(d)) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.

 

Item 12.

Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

 

Item 13.

Exhibits.

(a)(1) A copy of the Registrant’s Code of Ethics, as required by Item 2 of this Form, accompanies this filing as an exhibit.

(a)(2) A separate certification for the principal executive officer and the principal financial officer of the Registrant, as required by Rule 30a-2(a) under the Act (17 CFR § 270.30a-2(a)), is filed herewith.

(b) Officer certifications, as required by Rule 30a-2(b) under the Act (17 CFR § 270.30a-2(b)), also accompany this filing as an exhibit.

 


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

(Registrant)

      The Advisors’ Inner Circle Fund III
By (Signature and Title)      

/s/ Michael Beattie

     

Michael Beattie

President

Date: March 11, 2022      

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the Registrant and in the capacities and on the dates indicated.

 

By (Signature and Title)      

/s/ Michael Beattie

     

Michael Beattie

President

Date: March 11, 2022      

 

By (Signature and Title)      

/s/ Andrew Metzger

      Andrew Metzger
      Treasurer, Controller, and CFO
Date: March 11, 2022