January 16, 1991
TO: TRANSFER AGENT ADVISORY COMMITTEE NO. 2-91
RE: STATUS OF VARIOUS PROJECTS
__________________________________________________________
The status of each of the Advisory Committee’s projects is
summarized below.
1. Confirmation Requirements
Ralph Spuehler of Keystone will be sending a survey to the
Advisory Committee members in the near future to determine if
fund groups are in favor of a limited reduction in confirmation
requirements. The survey will suggest confirmation mailings be
reduced to quarterly where dividend reinvestment and/or
systematic transactions are the only account activity. Upon
conclusion of the survey a recommendation to the Institute’s
Operations Committee and legal department will be drafted, for
consideration in a possible letter to the SEC.
2. Returned by Post Office (RPO)
The task force has submitted to the Transfer Agent Advisory
Committee Chairman a document outlining discussion issues and
conclusions drawn in regard to the costs associated with RPO
accounts. The task force agrees it to be appropriate to pass
escheatment costs (which are now being allocated to all
shareholders) on to the actual (RPO) accounts involved, assuming
certain actions have been taken. At the next Advisory Committee
meeting these conclusions will be discussed and the appropriate
recommendations will be made to the Operations Committee and ICI
Legal Department to allow for the treatment of such costs.
The task force members are:
Cynthia Jones (Chairman) Colonial
Mary Bolles Keystone
Jim Olshefski DST
Sharyn Romm Delaware Group
Steve Warner Pioneer
3. Legal Requirements/TA Signature Guarantees Project
The first meeting of this reorganized task force was held
last week where significant progress was made analyzing the types
of legal requirements that exist for certain types of
transactions. The task force will meet again for an all day
working session on January 25th, 1990, to conclude its analyzes.
The group intends to define present industry practices (polled by
task force members) for certain activities and suggest which
activities could be engaged with less legal requirements. The
task force’s recommendations will suggest certain procedures that
each fund complex should be required to follow to reduce such
legal requirements. These recommendations will be presented at
the next Transfer Agent Advisory Committee meeting and will be
forwarded by Donald O’Connor to the ICI Mutual Underwriting
Committee for insurance coverage consideration. Members of this
task force are:
Cynthia Jones (Co-Chairman) Colonial
Janet Clifford (Co-Chairman) MFS
Ken Beard American Capital
Bob Blucke Fidelity
Mike Cady Pioneer
Lynn Haddad Pioneer
Mary Crooks Oppenheimer
Lynda DesEnfants American Funds
Valerie Hugo Alliance
Steve MacNeill Scudder
Linda Parsons U.S. Trust
Mark Rayford T. Rowe Price
Lizzy Heuisler T. Rowe Price
4. Transfer of Assets Survey
The sub-committee assigned to evaluate Industry trends and
practices relative to IRA Asset Transfers has completed it’s
survey. The sub-committee members who were supportive and active
in this endeavor include:
Joe Recomendes (Chairman) MFS
Janet A. Clifford MFS
Randall S. Gore DST
Nancee Koporc Kemper
Vincent Marra Prudential
Wayne O’Melia T. Rowe Price
The survey results and major conclusions drawn by the
subcommittee were distributed to the Advisory Committee members
on December 14, 1990. The sub-committee’s report outlines
several recommendations as to how to proceed in concluding this
project. The survey report will be discussed in detail at the
next Advisory Committee meeting. Comments or suggestions
regarding the survey results should be forwarded to Joe
Recomendes at MFS and Donald O’Connor at the Institute.
5. Tax Basis Accounting For Shareholders
The IDS Average Cost System was presented to the Transfer
Agent Advisory Committee by Jerry Amundson of IDS at the December
5th meeting. Barbara Moulding will be distributing a summary of
the work performed on this project to date and conclusions drawn
by the task force at the next Advisory Committee meeting.
6. Transfer Agent Regulatory Costs
An ad-hoc committee was formed to research and define the
cost of regulatory compliance as a component of total transfer
agent charges. Members of the ad-hoc group are:
Robert Guillocheau (Chairman) TSSG
Timothy Hayes Fidelity
Jim Olshefski DST
Ralph Spuehler Keystone
Barbara Hennigar Oppenheimer
The group is currently defining it’s objectives and intends
to make progress on this project in the next few weeks. It is
not known yet whether regulatory costs can be isolated. If this
is possible, such cost data might provide the statistical
evidence needed to suggest that imposed regulations have
contributed to the rising cost of doing business. This
information would be useful for both fund directors and
regulatory bodies. If the group is able to determine it is
beneficial to isolate regulatory costs, we will consider how this
can be achieved on an industry-wide basis and if possible
incorporate this into future transfer agent cost surveys.
7. Survey of Book Versus Physical Shares
This survey was circulated to Advisory Committee members on
November 29, 1990 to assist the Institute in it’s work as a
participant on the Group of Thirty U.S. Working Committee. The
purpose of the survey is to update our general understanding of
the form in which mutual fund shares are presently being issued
and the overall composition of shares (book versus physical)
outstanding. To date seven of the twenty-one surveys circulated
have been received. Follow-up calls have indicated that the
remainder of surveys should be received by the end of January.
Preliminary results will be presented at the next Advisory
Committee meeting.
****************************
Your contribution and your involvement on these projects is
greatly appreciated. We hope to make significant progress in
concluding the majority of the Transfer Agent Advisory Committee
projects in 1991.
The next Transfer Agent Advisory Committee meeting will be
held on March 5, 1991 in Washington, D.C. at 9:30 a.m. A
separate meeting notice was mailed by the Institute to committee
members on January 14, 1991. If you have not yet responded
whether you will be attending, please contact Rita Pemberton at
the Institute either by faxing (202/293-1058) or by phoning
(202/955-3551) in your response.
Thank you for your participation.
William H. Smith
Chairman
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