Victory Pioneer ILS Interval Fund

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

Interval FundInsurance-linked securities

Sponsor: Victory Capital / Pioneer
CIK: 0001616037
Liquidity: Periodic repurchase offers at NAV
Inception: 2015

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

Open the filing on SEC.gov · Full observation history

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)
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

Open the filing on SEC.gov · Full observation history

Technical locator

https://www.sec.gov/Archives/edgar/data/1616037/000119312526299389/f45749d1.htm | N-23c-3 informational NAV block
Net flows, last qtr: +1.5%
Distribution coverage (NII): 129%
Leverage in use: 0%
Total return, 12m: +26.5%

01 / Signals

What changed in the latest filings.

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

Notify

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

Notify

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.)

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.

$3.8M -> 26,349 (down 99.3% vs prior period); trailing 4-period average $3.3M; same period prior year 285,000; breach persisted 2 consecutive periods (escalated per the two-stage ladder)

Source: NPORT-P mon3Flow.sales | https://www.sec.gov/Archives/edgar/data/1616037/000094040025002591/xslFormNPORT-P_X01/primary_doc.xml

Historical findings (33)

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 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.)

02 / Trends

How the fund has moved.

Net asset value, total return, capital flows, and distribution coverage across the filing record.

Total return index

NAV per share

Net capital flows, % of NAV

Distribution coverage

03 / Portfolio

What moved inside the book.

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

No structured portfolio-health series or position-change events have been captured for this fund.

04 / Redemptions

Where exit demand met the cap.

Rationed in 1 of 19 disclosed periods; last gated Q4 2021.

Requested redemptions versus cap

Period	Requested	Filled	Cap used	Status
2026-05-18	3.4%	100%	34%	filled
2026-02-23	1.5%	100%	15%	filled
2025-12-03	2.6%	100%	26%	filled
2025-08-11	1.8%	100%	18%	filled
2025-05-19	3.0%	100%	30%	filled
2025-02-24	3.8%	100%	38%	filled
2024-12-04	4.6%	100%	46%	filled
2024-08-12	2.8%	100%	28%	filled
2024-05-20	2.4%	100%	24%	filled
2024-02-26	3.1%	100%	31%	filled
2023-11-27	5.1%	100%	51%	filled
2023-08-07	8.7%	100%	87%	filled
2023-05-15	9.2%	100%	77%	filled
2023-02-21	11.8%	100%	98%	filled
2022-11-28	11.7%	100%	98%	filled
2022-08-08	4.9%	100%	49%	filled
2022-05-16	5.9%	100%	59%	filled
2022-02-22	5.6%	100%	56%	filled
2021-11-29	12.3%	97%	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.

No structured financing components have been captured for this fund.

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.

No filed share-class terms have been captured for this fund; ownership type is therefore not inferred.

Management fee: 1.75% of avg daily net assets tiered per year. source. 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.

07 / Sources

The evidence beneath the page.

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

Term register (1)

Term	Description	Value	Effective
advisory_fee_schedule	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.	1.75 pct_annual_of_avg_daily_net_assets_tiered	Date not captured

Recent filings

Filed	Form	Accession
2026-07-09	N-23C3A	0001193125-26-299389
2026-07-06	N-CSRS	0001616037-26-000003
2026-06-25	NPORT-P	0001004726-26-005221
2026-04-17	N-23C3A	0001193125-26-160803
2026-04-01	NPORT-P	0000940400-26-012923
2026-01-23	N-23C3A	0001193125-26-020645
2026-01-06	N-CSR	0001193125-26-004485
2025-12-19	NPORT-P	0000940400-25-014050
2025-10-24	N-23C3A	0001193125-25-249445
2025-09-26	NPORT-P	0000940400-25-002591
2025-07-10	N-23C3A	0001683863-25-005687
2025-07-08	N-CSRS	0001193125-25-156492
2025-06-27	NPORT-P	0001752724-25-160641
2025-04-17	N-23C3A	0001616037-25-000007
2025-03-25	NPORT-P	0001752724-25-066329