Memo #
31250

Conference Call on Response to SEC Request for Comment on Processing Fees
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[31250]

June 19, 2018 TO: Operations Committee
SEC Rules Committee
Small Funds Committee
Transfer Agent Advisory Committee RE: Conference Call on Response to SEC Request for Comment on Processing Fees

 

As you know, the Commission recently requested comment on the overall framework for the processing fees that broker-dealers and other intermediaries charge funds as reimbursement for forwarding shareholder reports and other fund materials to investors that are beneficial owners of shares held in street name through the intermediary.[1] Comments are due to the Commission by October 31, 2018.

We are forming a working group to respond to this request for comment. Please RSVP to jodom@ici.org to be added to the Processing Fees Working Group list for future communications. We would appreciate if you could pass this information on to the appropriate contacts in your organization.

The working group’s initial call is scheduled for Tuesday, July 10, from 1:00-2:00 p.m. ET.

Dial-in: (888) 323-6172
Passcode: 69003

We expect to discuss the SEC’s requests for comment on the following:

  • Current processing fee structure, including the application of various processing fees and rates under the NYSE rules;
  • Transparency of these fees;
  • Practices related to the payment of these fees and remittances that financial intermediaries receive for delivery of fund documents (including shareholder reports); and
  • The appropriateness of these fees in cases where intermediaries are separately paid shareholder servicing fees from fund assets.

We will circulate a more detailed call agenda to those who RSVP.

 

Linda M. French
Assistant General Counsel

Joanne Kane
Director, Operations & Transfer Agency

 

endnotes

[1] Request for Comments on the Processing Fees Charged by Intermediaries For Distributing Materials Other Than Proxy Materials to Fund Investors, SEC Rel. Nos. 33-10505, 34-83379, IC-33114 (June 5, 2018), available at https://www.sec.gov/rules/other/2018/33-10505.pdf; ICI’s memorandum summarizing the request for comment is available at https://www.ici.org/my_ici/memorandum/ci.memo31243.idc.