May 11, 1992
TO: STATE LIAISON COMMITTEE NO. 19-92
UNIT INVESTMENT TRUST COMMITTEE NO. 27-92
RE: INSTITUTE REQUESTS VERMONT TO ADOPT INDEFINITE REGISTRATION
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Legislation has passed both houses of the Vermont
Legislature and is currently pending before the Governor which
substantially increases the registration fee for issuers of
securities. House Bill 601 increases the minimum registration
fee to $250 and the maximum registration fee to $1,000.
Currently, the registration fee in Vermont is a minimum of $50
and a maximum of $500.
The Institute has contacted both the Governor’s Office and
the Department of Banking, Insurance and Securities to discuss
the impact the fee increase would have on mutual funds and unit
trusts. The Deputy Director of the Department of Banking,
Insurance and Securities has indicated a willingness to
administratively adopt a "true indefinite" registration procedure
in order to alleviate the economic burden of the fee increase.
Under this procedure, a mutual fund or unit trust would be able
to register an indefinite amount of securities by payment of the
minimum fee. Within 60 days of the expiration of the issuer’s
registration statement, the fund or trust would submit a sales
report and any additional fees due. Such a procedure eliminates
the oversales problem and enables a fund or trust to pay a
registration fee based on actual sales in Vermont. A copy of the
Institute’s letter to the Deputy Director outlining this
procedure is attached.
We will keep you advised of developments.
Patricia Louie
Assistant General Counsel
Attachment