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February 8, 2006
TO: BOARD OF GOVERNORS No. 6-06
INDEPENDENT DIRECTORS COUNCIL 2-06
SEC RULES COMMITTEE No. 7-06
RE: ICI RESPONSE TO COALITION OF MUTUAL FUND INVESTORS LETTER TO FUND
TRUSTEES
The Institute recently responded to the letter sent by the Coalition of Mutual Fund
Investors (CMFI) to a number of mutual fund trustees regarding the use of omnibus
recordkeeping by mutual fund intermediaries. The ICI’s letter states that the issues raised in the
CMFI letter are largely addressed by the SEC’s new redemption fee rule. The letter notes that
the SEC staff and the fund industry continue to work on implementation issues under the new
rule and that the SEC is expected to issue additional guidance relating to the rule in the near
future. The ICI’s response also emphasizes that fund trustees take seriously their
responsibilities to oversee a fund’s compliance obligations, including those relating to the use of
omnibus accounts, for the protection of all shareholders.
A copy of the ICI’s letter is attached.
Amy B.R. Lancellotta
Senior Counsel - Securities Regulation
Attachment
Attachment (in .pdf format)