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Victory Pioneer ILS Interval Fund

Data through 2026-07-02 · latest filing N-23C3A filed 2026-07-09

Sponsored by Victory Capital / Pioneer. Interval Fund structure focused on insurance-linked securities.

Interval FundInsurance-linked securities

Sponsor
Victory Capital / Pioneer
CIK
0001616037
Liquidity
Quarterly repurchase offers at NAV
Inception
2014
Net assets
$823.2M
source

Semiannual shareholder report (Form N-CSRS) · filed 2026-07-06 · period 2026-04-30

Statement of Assets and Liabilities fund-level identity (Total assets - Total liabilities [- Preferred Shares] = Net Assets; no per-class breakdown template matched this filer agent)

“Total Assets 824,777 | Total Liabilities 1,550 | Net Assets $ 823,227”

Method Matched text template against the filing

Technical locator

https://www.sec.gov/Archives/edgar/data/1616037/000161603726000003/primary-document.htm | Statement of Assets and Liabilities fund-level identity (Total assets - Total liabilities [- Preferred Shares] = Net Assets; no per-class breakdown template matched this filer agent)

as of 2026-04-30
NAV / share
$10.53
source

Repurchase offer notice (Form N-23c-3) · filed 2026-07-09 · period 2026-07-02

N-23c-3 informational NAV block

“On July 2, 2026, the NAV per share of the Fund was $10.53”

Method Matched text template against the filing

Technical locator

https://www.sec.gov/Archives/edgar/data/1616037/000119312526299389/f45749d1.htm | N-23c-3 informational NAV block

Filed fund value · as of 2026-07-02
Net flows, last qtr
+1.5%
qtr ended 2026-03-31
Distribution coverage (NII)
129%
period ended 2025-10-31
Leverage in use
Unlevered
as of 2026-04-30; SEC source 0001616037-26-000003
Total return, 12m
Pending
SEC-filed periodic NAV + distributions
01 / Signals

What changed in the latest filings.

Current findings ordered by severity. Each observation remains traceable to its filed source.

Yellow flag

New share sales fell 74% versus the same period last year (137,590 -> 238,985, period ended 2025-10-31).

New share sales fell 74% versus the same period last year (137,590 -> 238,985, period ended 2025-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Why it matters and what changed

New sales have dropped sharply versus the same period last year. The fundraising flywheel funds liquidity: falling inflows make every future redemption harder to meet without selling assets.

502,936 -> 238,985 (down 52.5% vs prior period); trailing 4-period average $4.1M; same period prior year 137,590; breach persisted 2 consecutive periods (escalated per the two-stage ladder)

Source: NPORT-P mon3Flow.sales | https://www.sec.gov/Archives/edgar/data/1616037/000094040025014050/xslFormNPORT-P_X01/primary_doc.xml

Historical findings (35)

Redemptions prorated for the period ending 2021-11-29: 12.3% requested, only 97.3% of requests fulfilled. (2021-11-29)
Redemptions prorated for the period ending 2021-11-29: 12.3% requested, only 97.3% of requests fulfilled. The fund hit its redemption cap and rationed liquidity.

NAV per share fell 13.1% from $9.93 to $8.63 (2019-04-30).
NAV per share fell 13.1% from $9.93 to $8.63 (2019-04-30). (Rule B12: NAV per share drop, severe: >= 5% decline month over month; Urgent.)

NAV per share fell 8.1% from $10.43 to $9.59 (2017-10-31).
NAV per share fell 8.1% from $10.43 to $9.59 (2017-10-31). (Rule B12: NAV per share drop, severe: >= 5% decline month over month; Urgent.)

NAV per share fell 6.0% from $11.09 to $10.43 (2017-04-30).
NAV per share fell 6.0% from $11.09 to $10.43 (2017-04-30). (Rule B12: NAV per share drop, severe: >= 5% decline month over month; Urgent.)

New share sales fell 91% versus the same period last year (285,000 -> 26,349, period ended 2025-07-31).
New share sales fell 91% versus the same period last year (285,000 -> 26,349, period ended 2025-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 100% versus the same period last year (208,600 -> 0.00, period ended 2025-04-30).
New share sales fell 100% versus the same period last year (208,600 -> 0.00, period ended 2025-04-30). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 38% versus the same period last year (99,985 -> 137,590, period ended 2024-10-31).
New share sales fell 38% versus the same period last year (99,985 -> 137,590, period ended 2024-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 165% versus the same period last year (107,590 -> 285,000, period ended 2024-07-31).
New share sales fell 165% versus the same period last year (107,590 -> 285,000, period ended 2024-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 77% versus the same period last year (208,224 -> 48,000, period ended 2024-01-31).
New share sales fell 77% versus the same period last year (208,224 -> 48,000, period ended 2024-01-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 6.1% of NAV in the period ended 2023-08-31.
Net outflow of 6.1% of NAV in the period ended 2023-08-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

New share sales fell 49% versus the same period last year (72,187 -> 107,590, period ended 2023-07-31).
New share sales fell 49% versus the same period last year (72,187 -> 107,590, period ended 2023-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 6.6% of NAV in the period ended 2023-05-31.
Net outflow of 6.6% of NAV in the period ended 2023-05-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

New share sales fell 629% versus the same period last year (84,200 -> 614,013, period ended 2023-04-30).
New share sales fell 629% versus the same period last year (84,200 -> 614,013, period ended 2023-04-30). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 11.5% of NAV in the period ended 2023-03-31.
Net outflow of 11.5% of NAV in the period ended 2023-03-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

Net outflow of 9.5% of NAV in the period ended 2022-12-31.
Net outflow of 9.5% of NAV in the period ended 2022-12-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share fell 3.2% from $8.37 to $8.10 (2022-10-31).
NAV per share fell 3.2% from $8.37 to $8.10 (2022-10-31). (Rule B11: NAV per share drop >= 2% decline month over month; Notify.)

New share sales fell 64% versus the same period last year (202,152 -> 72,187, period ended 2022-07-31).
New share sales fell 64% versus the same period last year (202,152 -> 72,187, period ended 2022-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 6.2% of NAV in the period ended 2022-06-30.
Net outflow of 6.2% of NAV in the period ended 2022-06-30. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share ($8.37) is 2.2% below its trailing four-observation average ($8.56) as of 2022-04-30.
NAV per share ($8.37) is 2.2% below its trailing four-observation average ($8.56) as of 2022-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

Net outflow of 9.6% of NAV in the period ended 2021-12-31.
Net outflow of 9.6% of NAV in the period ended 2021-12-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

New share sales fell 103% versus the same period last year (35,139 -> 71,436, period ended 2021-10-31).
New share sales fell 103% versus the same period last year (35,139 -> 71,436, period ended 2021-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 30% versus the same period last year (156,024 -> 202,152, period ended 2021-07-31).
New share sales fell 30% versus the same period last year (156,024 -> 202,152, period ended 2021-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 5.9% of NAV in the period ended 2021-06-30.
Net outflow of 5.9% of NAV in the period ended 2021-06-30. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share fell 3.6% from $8.88 to $8.56 (2021-04-30).
NAV per share fell 3.6% from $8.88 to $8.56 (2021-04-30). (Rule B11: NAV per share drop >= 2% decline month over month; Notify.)

New share sales fell 23% versus the same period last year (28,500 -> 35,139, period ended 2020-10-31).
New share sales fell 23% versus the same period last year (28,500 -> 35,139, period ended 2020-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Gross share sales: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year [Notify, 2020-07-31]
Gross share sales triggered rule C13 for the period ending 2020-07-31.

Net outflow of 7.2% of NAV in the period ended 2020-06-30.
Net outflow of 7.2% of NAV in the period ended 2020-06-30. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share fell 3.8% from $8.79 to $8.46 (2020-04-30).
NAV per share fell 3.8% from $8.79 to $8.46 (2020-04-30). (Rule B11: NAV per share drop >= 2% decline month over month; Notify.)

NAV per share ($8.46) is 5.5% below its trailing four-observation average ($8.95) as of 2020-04-30.
NAV per share ($8.46) is 5.5% below its trailing four-observation average ($8.95) as of 2020-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

Net outflow of 7.2% of NAV in the period ended 2020-03-31.
Net outflow of 7.2% of NAV in the period ended 2020-03-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

Redemptions accelerated to $59.6M from $15.3M the prior period (period ended 2019-12-31).
Redemptions accelerated to $59.6M from $15.3M the prior period (period ended 2019-12-31). (Rule C14: Redemption acceleration: repurchase/redemption dollars up >= 25%; Notify.)

NAV per share ($8.79) is 4.9% below its trailing four-observation average ($9.24) as of 2019-10-31.
NAV per share ($8.79) is 4.9% below its trailing four-observation average ($9.24) as of 2019-10-31. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

NAV per share ($8.63) is 8.6% below its trailing four-observation average ($9.44) as of 2019-04-30.
NAV per share ($8.63) is 8.6% below its trailing four-observation average ($9.44) as of 2019-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

NAV per share ($9.93) is -0.4% below its trailing four-observation average ($9.89) as of 2018-10-31.
NAV per share ($9.93) is -0.4% below its trailing four-observation average ($9.89) as of 2018-10-31. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

NAV per share ($9.61) is 5.6% below its trailing four-observation average ($10.18) as of 2018-04-30.
NAV per share ($9.61) is 5.6% below its trailing four-observation average ($10.18) as of 2018-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

03 / Portfolio

What moved inside the book.

Filed portfolio-health facts and position changes. Missing disclosures stay visibly missing.

Pending

04 / Redemptions

Where exit demand met the cap.

Stated cap: 10% of shares/quarter. Rationed in 1 of 19 disclosed periods; last gated Q4 2021.

PeriodRequestedFilledCap usedStatus
2026-05-18Pending100%34%filled
2026-02-23Pending100%15%filled
2025-12-03Pending100%26%filled
2025-08-11Pending100%18%filled
2025-05-19Pending100%30%filled
2025-02-24Pending100%37%filled
2024-12-04Pending100%46%filled
2024-08-12Pending100%28%filled
2024-05-20Pending100%24%filled
2024-02-26Pending100%31%filled
2023-11-27Pending100%51%filled
2023-08-07Pending100%Pendingfilled
2023-05-15Pending100%Pendingfilled
2023-02-21Pending100%Pendingfilled
2022-11-28Pending100%Pendingfilled
2022-08-08Pending100%Pendingfilled
2022-05-16Pending100%Pendingfilled
2022-02-22Pending100%Pendingfilled
2021-11-29Pending97%100%rationed
05 / Financing

How the balance sheet is funded.

Borrowings, unused capacity, and synthetic exposure are separated so unlike risks do not collapse into one ratio.

Pending

06 / Share classes

How the offering is divided.

A filed share-class breakdown and terms-based role descriptions. This is not an estimate of who owns the fund.

Not attributed 100.0%

Share of total net assets ($823,227,000) as of 2026-04-30; the hatched band is net assets the filings do not attribute to a captured class.

ClassTerms-based role descriptionLoadServicingMinimumAssets
Common sharesPendingPendingPendingPendingPending

Management fee: 1.75% of avg daily net assets tiered per year, current as of latest filed disclosure. Research only: not used in a fee distribution. SEC source 0001193125-26-004485.

Filed fee conditions

Management fees payable under the Fund's Investment Advisory Agreement with the Adviser are calculated daily and paid monthly at the annual rate of 1.75% of the Fund's average daily net assets up to $1 billion, and 1.70% of the Fund's average daily net assets over $1 billion. For the year ended October 31, 2025, the effective management fee was equivalent to 1.75% of the Fund's average daily net assets (the Fund's net assets have not yet crossed the $1 billion tier threshold) -- not a documented skip, since the filing itself states this current effective rate. Effective April 1, 2025 the Adviser has separately contractually agreed to waive fees/reimburse expenses so total annual fund operating expenses do not exceed 1.93%, through April 1, 2028.

Canonical-class fee profile
ClassManagementIncentiveLoadServicingGross expensesNet expenses
Common shares 1.75% None
*
None. The standardized prospectus fee table contains no incentive/performance-fee line.
SEC source 0001193125-26-266096
Pending Pending Pending 1.91%filed basis
*
Filed label: Ratio of net expenses to average net assets; period 2025-10-31.
After waiver: not separately stated; interest: not separately stated; tax: not separately stated; incentive compensation: not separately stated; acquired-fund expenses: not separately stated.
SEC source 0001193125-26-004485

Expense-ratio caution. These are the issuer’s filed figures for the designated analysis class. They are not placed in a fee ranking because denominators and included expenses are not yet normalized across funds. Hover or click * for the filed label, period, components, and SEC source.

07 / Sources

The evidence beneath the page.

Filed terms and recent documents remain available without crowding the primary research flow.

Term register (1)
TermDescriptionValueEffective
advisory_fee_scheduleManagement fees payable under the Fund's Investment Advisory Agreement with the Adviser are calculated daily and paid monthly at the annual rate of 1.75% of the Fund's average daily net assets up to $1 billion, and 1.70% of the Fund's average daily net assets over $1 billion. For the year ended October 31, 2025, the effective management fee was equivalent to 1.75% of the Fund's average daily net assets (the Fund's net assets have not yet crossed the $1 billion tier threshold) -- not a documented skip, since the filing itself states this current effective rate. Effective April 1, 2025 the Adviser has separately contractually agreed to waive fees/reimburse expenses so total annual fund operating expenses do not exceed 1.93%, through April 1, 2028.1.75 pct_annual_of_avg_daily_net_assets_tieredPending
Recent filings
FiledFormAccession
2026-07-09N-23C3A0001193125-26-299389
2026-07-06N-CSRS0001616037-26-000003
2026-06-25NPORT-P0001004726-26-005221
2026-06-10486BPOS0001193125-26-266096
2026-04-17N-23C3A0001193125-26-160803
2026-04-01NPORT-P0000940400-26-012923
2026-03-054970001193125-26-093427
2026-01-23N-23C3A0001193125-26-020645
2026-01-06N-CSR0001193125-26-004485
2025-12-19NPORT-P0000940400-25-014050
2025-12-154970001193125-25-319127
2025-11-264970001193125-25-298641
2025-10-24N-23C3A0001193125-25-249445
2025-10-094970001193125-25-235736
2025-09-26NPORT-P0000940400-25-002591