Embassy files The Envoy Fund as a futures mutual fund on IMST II

The SEC recorded the paper at 2:30 p.m. Eastern on Friday, September 11: Form 485APOS, a post-effective amendment under Rule 485(a), proposing The Envoy Fund as a new series of Investment Managers Series Trust II. The adviser is Embassy Asset Management LP, the Short Hills, New Jersey, firm that already runs mutual funds on the same trust. The prospectus is stamped “Subject to Completion.” Tickers are blank. The securities may not be sold until the registration statement is effective.

This is a registration, not a listing.

What the paper actually commits to

The Envoy Fund would seek long-term capital appreciation. Its principal strategy, as written, invests in equities, commodities, currencies and fixed income, typically through U.S. exchange-traded futures, using a proprietary, generally systematic and rules-based allocation model that reads momentum signals. That is the same four-asset futures sleeve ETF issuers sell as managed futures. Embassy is not wrapping it as an ETF.

The fund would have two classes, Institutional Class Shares and Class S Shares, with ticker fields left as “[ ].” There is no maximum sales charge on purchases for either class. Class S Shares would pay distribution and shareholder-liaison service fees, including Rule 12b-1 fees of up to 0.25% of average daily net assets attributable to that class. Institutional Class Shares would not. The filing includes a Rule 12b-1 plan and a Rule 18f-3 plan, the document that lets one fund offer more than one share class.

The fee table is unfinished. The advisory fee is described only as a percentage of average daily net assets to be specified in the prospectus. The after-waiver line is filled in at 0.80% for both Institutional Class and Class S. The expense-limitation agreement that produces that number caps total annual fund operating expenses at 0.80% of average daily net assets of the Fund, and it excludes Rule 12b-1 fees and shareholder servicing fees. The agreement runs through a date in 2027 that is still blank. Holders would not yet know the contractual advisory rate.

The other exhibit that changes the product is an investment advisory agreement with The Envoy Fund Ltd., the Cayman Islands subsidiary commodity-futures funds use so the onshore series can hold the contracts without breaking the tax rules for a U.S. regulated investment company.

The paper asks to become effective 75 days after filing under Rule 485(a)(2). Counted from Friday, that clock runs into late November, and only if the Commission does not comment and the registrant does not pull or recut the paper. This one still has blanks where a finished prospectus would have numbers.

Embassy’s Ambassador Fund on the same trust

Embassy already uses Investment Managers Series Trust II for mutual funds, not ETFs. The Ambassador Fund, an insurance-linked securities portfolio, launched on this platform with the same two-class design, Institutional and Class S, and the same distributor, IMST Distributors, LLC, which is not affiliated with Embassy. Ambassador held almost $418 million as of January 31, 2025, and almost $900 million by the week of July 8, 2026. The Institutional Class expense ratio is 1.39%; Class S is 1.64%, 0.25 percentage points higher. The firm’s site also lists The Diplomat Fund.

Friday’s paper is Post-Effective Amendment No. 633 under the Securities Act of 1933, a running count of how often this trust recuts its registration. In May 2023, the SEC granted Embassy and the trust an order to hire and replace subadvisers without a shareholder vote.

Envoy reuses that chassis: two classes, a 12b-1-paying Class S, Institutional without it, the same unaffiliated distributor. Embassy gathered the Ambassador assets through the mutual-fund wrapper and its distribution class. Whether Envoy is a distribution bet is still the open question. The paper does not say why now, and no issuer comment accompanied the filing. What the documents show is a mutual-fund adviser putting a systematic futures product into the two-class structure it already operates, rather than into an ETF wrapper.

The ETF sleeve this would sit beside

The large managed-futures ETFs already do, in exchange-traded form, what Envoy’s prospectus describes: long and short futures across equities, rates, currencies and commodities. iMGP’s four-asset fund BDBMF holds $4.27 billion and charges 0.85%. Simplify’s systematic fund BCTA holds $1.59 billion at 0.75%. Fidelity’s managed-futures ETF BFFUT, incepted in June 2025, holds $352 million at 0.82%. WisdomTree’s rules-based fund AWTMF is the cheap end of this group at 0.65%. J.P. Morgan’s BJPFP, which opened in May, mixes a managed-futures sleeve with U.S. large-cap stocks and lists a 0.59% expense ratio; it is a hybrid, not a clean comparison.

If Institutional holders pay the paper’s 0.80% operating-expense ceiling, that share would sit in the middle of that ETF fee range: cheaper than BDBMF and KraneShares’ Mount Lucas tracker CKMLM (0.90%), matching Virtus’s AlphaSimplex fund CASMF at 0.80%, and richer than AWTMF. Class S can cost more: the cap excludes 12b-1 fees of up to 0.25%.

Assets and expense ratios are the latest reported figures, as of September 13 and September 14. The table is the competitive set, not a prediction that Envoy will gather any of it. Mutual-fund shares are bought and redeemed at net asset value through the fund, not traded on an exchange.

J.P. Morgan, launching BJPFP in May, put the pitch in one sentence: managed futures have historically shown low correlation to both stocks and bonds, “suitable for advisors looking for ways to diversify beyond traditional portfolios.” Embassy’s filing does not make that argument. It describes a momentum model and a futures book.

An adviser that now runs almost $900 million in a catastrophe-bond mutual fund is building its next product in the same chassis, while the same futures strategy already trades on the exchange. The 12b-1 plan is what this registration files that an ETF would not.