January 16, 1990
TO: UNIT INVESTMENT TRUST MEMBERS NO. 2-90
RE: MASSACHUSETTS RE-INTERPRETS FEE POLICY
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The Institute has learned that Massachusetts recently
changed its interpretation of the manner in which registration
fees are calculated. Previously, pursuant to a Notice issued by
the Massachusetts Securities Division, unit trusts paid a filing
fee of one-twentieth of one percent of the aggregate amount of
the offering in Massachusetts, with a minimum fee of $300 and a
maximum fee of $1,500 for initial or amended registrations of
public offerings.
The Securities Division is now taking the position that
calculation of the filing fee for initial or amended
registrations of public offerings is to be based upon the
aggregate amount of the offering nationwide and not upon the
aggregate amount of the offering in Massachusetts. This change
in policy essentially means that the Securities Division will be
charging the maximum fee of $1,500 for each series of a unit
trust. The new policy has not yet been published but has been
put into effect.
The Institute is attempting to remedy this situation with
the Securities Division. We will keep you informed of further
developments.
Patricia Louie
Assistant General Counsel