Proposed Collection; Comment Request, 70517-70519 [2011-29253]
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Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
240.17Ad–7) under the Securities
Exchange Act of 1934 (15 U.S.C. 78a et
seq.) (‘‘Exchange Act’’). The
Commission plans to submit this
existing collection of information to the
Office of Management and Budget for
extension and approval.
Rule 17Ad–6 requires every registered
transfer agent to make and keep current
records about a variety of information,
such as: (1) Specific operational data
regarding the time taken to perform
transfer agent activities (to ensure
compliance with the minimum
performance standards in Rule 17Ad–2
(17 CFR 240.17Ad–2); (2) written
inquiries and requests by shareholders
and broker-dealers and response time
thereto; (3) resolutions, contracts or
other supporting documents concerning
the appointment or termination of the
transfer agent; (4) stop orders or notices
of adverse claims to the securities; and
(5) all canceled registered securities
certificates.
Rule 17Ad–7 requires each registered
transfer agent to retain the records
specified in Rule 17Ad–6 in an easily
accessible place for a period of six
months to six years, depending on the
type of record or document. Rule 17Ad–
7 also specifies the manner in which
records may be maintained using
electronic, microfilm, and microfiche
storage methods.
These recordkeeping requirements are
designed to ensure that all registered
transfer agents are maintaining the
records necessary for them to monitor
and keep control over their own
performance and for the Commission to
adequately examine registered transfer
agents on an historical basis for
compliance with applicable rules.
The Commission estimates that
approximately 473 registered transfer
agents will spend a total of 236,500
hours per year complying with Rules
17Ad–6 and 17Ad–7 (500 hours per year
per transfer agent).
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
Commission, including whether the
information shall have practical utility;
(b) the accuracy of the Commission’s
estimates of the burden of the proposed
collection of information; (c) ways to
enhance the quality, utility, and clarity
of the information on respondents; and
(d) ways to minimize the burden of the
collection of information on
respondents, including through the use
of automated collection techniques or
other forms of information technology.
Consideration will be given to
comments and suggestions submitted in
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writing within 60 days of this
publication.
The Commission may not conduct or
sponsor a collection of information
unless it displays a currently valid
control number. No person shall be
subject to any penalty for failing to
comply with a collection of information
subject to the PRA that does not display
a valid Office of Management and
Budget control number.
Please direct your written comments
to: Thomas Bayer, Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 6432 General Green Way,
Alexandria, Virginia 22312 or send an
email to: PRA_Mailbox@sec.gov.
Dated: November 7, 2011.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2011–29252 Filed 11–10–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Proposed Collection; Comment
Request
Upon Written Request, Copies
Available From: Securities and
Exchange Commission, Office of
Investor Education and Advocacy,
Washington, DC 20549–0213.
Extension:
Rule 22c–2, SEC File No. 270–541, OMB
Control No. 3235–0620.
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.) the Securities
and Exchange Commission (the
‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval.
Rule 22c–2 (17 CFR 270.22c–2
‘‘Mutual Fund Redemption Fees’’)
under the Investment Company Act of
1940 (15 U.S.C. 80a) (the ‘‘Investment
Company Act’’ or ‘‘Act’’) requires the
board of directors (including a majority
of independent directors) of most
registered investment companies
(‘‘funds’’) to either approve a
redemption fee of up to two percent or
determine that imposition of a
redemption fee is not necessary or
appropriate for the fund. Rule 22c–2
also requires a fund to enter into written
agreements with their financial
intermediaries (such as broker-dealers
and retirement plan administrators)
under which the fund, upon request,
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70517
can obtain certain shareholder identity
and trading information from the
intermediaries. The written agreement
must also allow the fund to direct the
intermediary to prohibit further
purchases or exchanges by specific
shareholders that the fund has
identified as being engaged in
transactions that violate the fund’s
market timing policies. These
requirements enable funds to obtain the
information that they need to monitor
the frequency of short-term trading in
omnibus accounts and enforce their
market timing policies.
The rule includes three ‘‘collections
of information’’ within the meaning of
the Paperwork Reduction Act of 1995
(‘‘PRA’’).1 First, the rule requires boards
to either approve a redemption fee of up
to two percent or determine that
imposition of a redemption fee is not
necessary or appropriate for the fund.
Second, funds must enter into
information sharing agreements with all
of their ‘‘financial intermediaries’’ 2 and
maintain a copy of the written
information sharing agreement with
each intermediary in an easily
accessible place for six years. Third,
pursuant to the information sharing
agreements, funds must have systems
that enable them to request frequent
trading information upon demand from
their intermediaries, and to enforce any
restrictions on trading required by funds
under the rule.
The collections of information created
by Rule 22c–2 are necessary for funds to
effectively assess redemption fees,
enforce their policies in frequent
trading, and monitor short-term trading,
including market timing, in omnibus
accounts. These collections of
information are mandatory for funds
that redeem shares within seven days of
purchase. The collections of information
also are necessary to allow Commission
staff to fulfill its examination and
oversight responsibilities.
Rule 22c–2(a)(1) requires the board of
directors of all registered investment
1 44
U.S.C. 3501–3520.
rule defines a Financial Intermediary as: (i)
Any broker, dealer, bank, or other person that holds
securities issued by the fund in nominee name; (ii)
a unit investment trust or fund that invests in the
fund in reliance on section 12(d)(i)(E) of the Act;
and (iii) in the case of a participant directed
employee benefit plan that owns the securities
issued by the fund, a retirement plan’s
administrator under section 316(A) of the Employee
Retirement Security Act of 1974 (29 U.S.C.
1002(16)(A) or any person that maintains the plans’
participant records. Financial Intermediary does not
include any person that the fund treats as an
individual investor with respect to the fund’s
policies established for the purpose of eliminating
or reducing any dilution of the value of the
outstanding securities issued by the fund. Rule 22c–
2(c)(1).
2 The
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Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
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companies and series thereof (except for
money market funds, ETFs, or funds
that affirmatively permit short-term
trading of its securities) to approve a
redemption fee for the fund, or instead
make a determination that a redemption
fee is either not necessary or appropriate
for the fund. Commission staff
understands that the boards of all funds
currently in operation have undertaken
this process for the funds they currently
oversee, and the rule does not require
boards to review this determination
periodically once it has been made.
Accordingly, we expect that only boards
of newly registered funds or newly
created series thereof would undertake
this determination. Commission staff
estimates that approximately 117 funds
or series thereof (excluding money
market funds and ETFs) are newly
formed each year and would need to
make this determination.
Based on conversations with fund
representatives,3 Commission staff
estimates that it takes approximately 2
hours of the boards’ time, as a whole, to
approve a redemption fee or make the
required determination. In addition,
Commission staff estimates that it takes
compliance personnel of the fund
approximately 8 hours to prepare
trading, compliance, and other
information regarding the fund’s
operations to enable the board to make
its determination, and takes internal
counsel of the fund approximately 3
hours to review this information and
present its recommendations to the
board. Therefore, for each fund board
that undertakes this determination
process, Commission staff estimates it
expends approximately 13 hours.4 As a
result, Commission staff estimates that
the total time spent for all funds on this
process is 1521 hours.5
Rule 22c–2(a)(2) requires a fund to
enter into information sharing
agreements with each of its financial
intermediaries. Commission staff
understands that all currently registered
funds have already entered into such
agreements with their intermediaries.
Funds enter into new relationships with
intermediaries from time to time,
however, which requires them to enter
into new information sharing
agreements. Commission staff
understands that, in general, funds enter
into information-sharing agreement
3 Unless otherwise stated, estimates throughout
this analysis are derived from a survey of funds and
conversations with fund representatives.
4 This calculation is based on the following
estimate: (2 hours of board time + 3 hours of
internal counsel time + 8 hours of compliance time
= 13 hours).
5 This calculation is based on the following
estimate: (13 hours × 117 funds = 1521 hours).
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when they initially establish a
relationship with an intermediary,
which is typically executed as an
addendum to the distribution
agreement. Commission staff estimates
that there are approximately 6911 openend fund series currently in operation
(excluding money market funds and
ETFs). However, the Commission staff
understands that most shareholder
information agreements are entered into
by the fund group (a group of funds
with a common investment adviser),
and estimates that there are currently
669 currently active fund groups.6
Commission staff estimates that, on
average, each active fund group enters
into relationships with approximately 3
new intermediaries each year.
Commission staff understands that
funds generally use a standard
information sharing agreement, drafted
by the fund or an outside entity, and
modifies that agreement according to
the requirements of each intermediary.
Commission staff estimates that
negotiating the terms and entering into
an information sharing agreement takes
a total of approximately 4 hours of
attorney time per intermediary
(representing 2.5 hours of fund attorney
time and 1.5 hours of intermediary
attorney time). Accordingly,
Commission staff estimates that each
existing fund group expends 12 hours
each year 7 to enter into new
information sharing agreements, and all
existing fund groups incur a total of
8028 hours.8
In addition, newly created funds
advised by new entrants (effectively
new fund groups) must enter into
information sharing agreements with all
of their financial intermediaries.
Commission staff estimates that there
are approximately 40 new funds or fund
groups that form each year that will
have to enter into information sharing
agreements with each of their
intermediaries.9 Commission staff
estimates that funds and fund groups
formed by new advisers typically have
relationships with significantly fewer
intermediaries than existing fund
groups, and estimates that new fund
groups will typically enter into
approximately 100 information sharing
agreements with their intermediaries
6 ICI, 2011 Investment Company Fact Book at Fig
1.7 (2011) (https://www.ici.org/stats/latest/2011_
factbook.pdf).
7 This estimate is based on the following
calculation: (4 hours × 3 new intermediaries = 12
hours).
8 This estimate is based on the following
calculation: (12 hours × 669 fund groups = 8028
hours).
9 ICI, 2011 Investment Company Fact Book at Fig
1.7 (2011) (https://www.ici.org/stats/latest/
2011_factbook.pdf).
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when they begin operations.10 As
discussed previously, Commission staff
estimates that it takes approximately 4
hours of attorney time per intermediary
to enter into information sharing
agreements. Therefore, Commission staff
estimates that each newly formed fund
group will incur 400 hours of attorney
time,11 and all newly formed fund
groups will incur a total of 16,000 hours
to enter into information sharing
agreements with their intermediaries.12
Rule 22c–2(a)(3) requires funds to
maintain records of all information
sharing agreements for 6 years in an
easily accessible place. Commission
staff estimates that there are
approximately 6911 open-end fund
series currently in operation (excluding
money market funds and ETFs).
However, the Commission staff
anticipates that most shareholder
information agreements will be stored at
the fund group level and estimates that
there are currently approximately 669
fund groups. Commission staff
understands that information-sharing
agreements are generally included as
addendums to distribution agreements
between funds and their intermediaries,
and that these agreements would be
stored as required by the rule as a matter
of ordinary business practice. Therefore,
Commission staff estimates that
maintaining records of information
sharing agreements requires
approximately 10 minutes of time spent
by a general clerk per fund, each year.
Accordingly, Commission staff
estimates that all funds will incur
approximately 112 hours 13 in
complying with the recordkeeping
requirement of rule 22c–2(a)(3).
Therefore, Commission staff estimates
that to comply with the information
sharing agreement requirements of rule
22c–2(a)(1) and (3), it requires a total of
24,140 hours.14
The Commission staff estimates that
on average, each fund group requests
shareholder information once a week,
and gives instructions regarding the
restriction of shareholder trades every
day, for a total of 417 responses related
10 Commission staff understands that funds
generally use a standard information sharing
agreement, drafted by the fund or an outside entity,
and then modifies that agreement to according the
requirements of each intermediary.
11 This estimate is based on the following
calculation: (4 hours × 100 intermediaries = 400
hours).
12 This estimate is based on the following
calculation: (40 fund groups × 400 hours = 16,000
hours).
13 This estimate is based on the following
calculation: (10 minutes × 669 fund groups = 6690
minutes); (6690 minutes/60 = 112 hours).
14 This estimate is based on the following
calculation: (8028 hours + 16,000 hours + 112 hours
= 24,140 hours).
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Federal Register / Vol. 76, No. 219 / Monday, November 14, 2011 / Notices
to information sharing systems per fund
group each year, and a total 278,973
responses for all fund groups
annually.15 In addition, the staff
estimates that funds make 117 responses
related to board determinations, 2007
responses related to new intermediaries
of existing fund groups, 4000 responses
related to new fund group information
sharing agreements, and 669 responses
related to recordkeeping, for a total of
6793 responses related to the other
requirements of rule 22c–2. Therefore,
the Commission staff estimates that the
total number of responses is 285,766
(278,973 + 6793 = 285,766). The
Commission staff estimates that the total
hour burden for rule 22c–2 is 25,661
hours.16
Rule 22c–2 requires funds to enter
into information sharing agreements
with their intermediaries that enable
funds to, upon request (i) be provided
certain information regarding
shareholders and their trades that are
held through a financial intermediary or
an indirect intermediary, and (ii) require
the intermediary to execute instructions
from the fund restricting or prohibiting
further purchases or exchanges by
shareholders that violate the fund’s
frequent trading policies. As a result of
this requirement, some funds and
intermediaries have had to develop and
maintain information sharing,
monitoring, and order execution
systems (collectively ‘‘information
sharing systems’’). In general, costs
related to these information-sharing
systems are borne at the fund group
level.
The Commission understands that all
currently operating funds and
intermediaries have either developed
information systems themselves or
purchased them from third parties.
However, these funds and
intermediaries also incur certain
ongoing costs related to these systems’
maintenance and operation. The
Commission staff understands that
various organizations have developed,
enhancements to their systems that
allow funds and intermediaries to share
the information required by the rule
without developing or maintaining
systems of their own. Other
organizations have developed ‘‘22c–2
solution’’ systems that funds may lease.
The Commission staff understands that
most funds and intermediaries use these
outside systems. In general, the staff
15 This estimate is based on the following
calculations: (52 + 365 = 417); (417 × 669 fund
groups = 278,973).
16 This estimate is based on the following
calculation: (1521 hours (board determination) +
24,140 hours (information sharing agreements) =
25,661 total hours).
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estimates that the typical charges
involved in operating and maintaining
information sharing systems average 25
cents for every 100 account transactions
requested. These systems generally also
provide analytics, spreadsheets, and
other tools designed to enable funds to
analyze the data presented, as well as
communication tools to process fund
instructions regarding the restrictions
and prohibitions they may request.
Commission staff estimates that the
costs of developing, maintaining and
operating information systems for funds
and intermediaries that do not use
outside provider’s systems is
comparable to the costs charged by
outside providers.17 The Commission
staff estimates that, on average, each
fund group requests information for
100,000 transactions each week,
incurring costs of $250 weekly, or
$13,000 a year.18 In addition, the
Commission staff estimates that funds
pay access fees to use these information
sharing systems (or comparable internal
costs) of approximately $30,000 each
year. The Commission staff therefore
estimates that a fund group would
typically incur approximately $43,000
in costs each year related to the
operation and maintenance of
information sharing systems required by
rule 22c–2. The Commission staff has
previously estimated that there are
approximately 669 fund groups
currently active, and therefore estimates
that all fund groups incur a total of
$28,767,000 in ongoing costs each year
related to maintaining and operating
information sharing systems.19
In addition, newly formed funds and
fund groups advised by advisers who
are new entrants would also need to
incur certain additional costs related to
the initial development or purchase of
these information-sharing systems.
Commission staff estimates that it
requires approximately $100,000 to
purchase or develop and implement
such an information sharing system for
the first time. Commission staff has
previously estimated that approximately
40 funds or fund groups are formed each
year managed by new advisers, and
17 We
include the burden for funds that develop
and operate these information sharing systems
internally rather than purchasing them from third
parties as a cost rather than as an hourly burden
because Commission staff understands that, even
when developing these systems themselves, funds
generally either use independent contractors or hire
new personnel, and thereby incur this burden as a
cost, not an hourly expenditure.
18 This estimate is based on the following
calculations: (100,000 transaction requests ×
0.0025¢ = $250); ($250 × 52 weeks = $13,000).
19 This estimate is based on the following
calculation: (669 fund groups × $43,000 =
$28,767,000).
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70519
therefore estimates that all these funds
would incur total costs of approximately
$4,000,000.20 Therefore the staff
estimates that the total costs related to
rule 22c–2 would be approximately
$32,767,000 ($28,767,000 + $4,000,000
= $32,767,000).
Responses provided to the
Commission will be accorded the same
level of confidentiality accorded to
other responses provided to the
Commission in the context of its
examination and oversight program.
Responses provided in the context of
the Commission’s examination and
oversight program are generally kept
confidential. Complying with the
information collections of rule 22c–2 is
mandatory for funds that redeem their
shares within 7 days of purchase. An
agency may not conduct or sponsor, and
a person is not required to respond to
a collection of information unless it
displays a currently valid control
number.
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information will have practical utility;
(b) the accuracy of the agency’s estimate
of the burden of the collection of
information; (c) ways to enhance the
quality, utility, and clarity of the
information collected; and (d) ways to
minimize the burden of the collection of
information on respondents, including
through the use of automated collection
techniques or other forms of information
technology. Consideration will be given
to comments and suggestions submitted
in writing within 60 days of this
publication.
Please direct your written comments
to Thomas Bayer, Director/Chief
Information Officer, Securities and
Exchange Commission, C/O Remi
Pavlik-Simon, 6432 General Green Way,
Alexandria, VA 22312; or send an email
to: PRA_Mailbox@sec.gov.
Dated: November 7, 2011.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2011–29253 Filed 11–10–11; 8:45 am]
BILLING CODE 8011–01–P
20 This estimate is based on the following
estimate: ($100,000 × 40 new fund groups =
$4,000,000).
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Agencies
[Federal Register Volume 76, Number 219 (Monday, November 14, 2011)]
[Notices]
[Pages 70517-70519]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-29253]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
Proposed Collection; Comment Request
Upon Written Request, Copies Available From: Securities and
Exchange Commission, Office of Investor Education and Advocacy,
Washington, DC 20549-0213.
Extension:
Rule 22c-2, SEC File No. 270-541, OMB Control No. 3235-0620.
Notice is hereby given that pursuant to the Paperwork Reduction Act
of 1995 (44 U.S.C. 3501 et seq.) the Securities and Exchange Commission
(the ``Commission'') is soliciting comments on the collection of
information summarized below. The Commission plans to submit this
existing collection of information to the Office of Management and
Budget for extension and approval.
Rule 22c-2 (17 CFR 270.22c-2 ``Mutual Fund Redemption Fees'') under
the Investment Company Act of 1940 (15 U.S.C. 80a) (the ``Investment
Company Act'' or ``Act'') requires the board of directors (including a
majority of independent directors) of most registered investment
companies (``funds'') to either approve a redemption fee of up to two
percent or determine that imposition of a redemption fee is not
necessary or appropriate for the fund. Rule 22c-2 also requires a fund
to enter into written agreements with their financial intermediaries
(such as broker-dealers and retirement plan administrators) under which
the fund, upon request, can obtain certain shareholder identity and
trading information from the intermediaries. The written agreement must
also allow the fund to direct the intermediary to prohibit further
purchases or exchanges by specific shareholders that the fund has
identified as being engaged in transactions that violate the fund's
market timing policies. These requirements enable funds to obtain the
information that they need to monitor the frequency of short-term
trading in omnibus accounts and enforce their market timing policies.
The rule includes three ``collections of information'' within the
meaning of the Paperwork Reduction Act of 1995 (``PRA'').\1\ First, the
rule requires boards to either approve a redemption fee of up to two
percent or determine that imposition of a redemption fee is not
necessary or appropriate for the fund. Second, funds must enter into
information sharing agreements with all of their ``financial
intermediaries'' \2\ and maintain a copy of the written information
sharing agreement with each intermediary in an easily accessible place
for six years. Third, pursuant to the information sharing agreements,
funds must have systems that enable them to request frequent trading
information upon demand from their intermediaries, and to enforce any
restrictions on trading required by funds under the rule.
---------------------------------------------------------------------------
\1\ 44 U.S.C. 3501-3520.
\2\ The rule defines a Financial Intermediary as: (i) Any
broker, dealer, bank, or other person that holds securities issued
by the fund in nominee name; (ii) a unit investment trust or fund
that invests in the fund in reliance on section 12(d)(i)(E) of the
Act; and (iii) in the case of a participant directed employee
benefit plan that owns the securities issued by the fund, a
retirement plan's administrator under section 316(A) of the Employee
Retirement Security Act of 1974 (29 U.S.C. 1002(16)(A) or any person
that maintains the plans' participant records. Financial
Intermediary does not include any person that the fund treats as an
individual investor with respect to the fund's policies established
for the purpose of eliminating or reducing any dilution of the value
of the outstanding securities issued by the fund. Rule 22c-2(c)(1).
---------------------------------------------------------------------------
The collections of information created by Rule 22c-2 are necessary
for funds to effectively assess redemption fees, enforce their policies
in frequent trading, and monitor short-term trading, including market
timing, in omnibus accounts. These collections of information are
mandatory for funds that redeem shares within seven days of purchase.
The collections of information also are necessary to allow Commission
staff to fulfill its examination and oversight responsibilities.
Rule 22c-2(a)(1) requires the board of directors of all registered
investment
[[Page 70518]]
companies and series thereof (except for money market funds, ETFs, or
funds that affirmatively permit short-term trading of its securities)
to approve a redemption fee for the fund, or instead make a
determination that a redemption fee is either not necessary or
appropriate for the fund. Commission staff understands that the boards
of all funds currently in operation have undertaken this process for
the funds they currently oversee, and the rule does not require boards
to review this determination periodically once it has been made.
Accordingly, we expect that only boards of newly registered funds or
newly created series thereof would undertake this determination.
Commission staff estimates that approximately 117 funds or series
thereof (excluding money market funds and ETFs) are newly formed each
year and would need to make this determination.
Based on conversations with fund representatives,\3\ Commission
staff estimates that it takes approximately 2 hours of the boards'
time, as a whole, to approve a redemption fee or make the required
determination. In addition, Commission staff estimates that it takes
compliance personnel of the fund approximately 8 hours to prepare
trading, compliance, and other information regarding the fund's
operations to enable the board to make its determination, and takes
internal counsel of the fund approximately 3 hours to review this
information and present its recommendations to the board. Therefore,
for each fund board that undertakes this determination process,
Commission staff estimates it expends approximately 13 hours.\4\ As a
result, Commission staff estimates that the total time spent for all
funds on this process is 1521 hours.\5\
---------------------------------------------------------------------------
\3\ Unless otherwise stated, estimates throughout this analysis
are derived from a survey of funds and conversations with fund
representatives.
\4\ This calculation is based on the following estimate: (2
hours of board time + 3 hours of internal counsel time + 8 hours of
compliance time = 13 hours).
\5\ This calculation is based on the following estimate: (13
hours x 117 funds = 1521 hours).
---------------------------------------------------------------------------
Rule 22c-2(a)(2) requires a fund to enter into information sharing
agreements with each of its financial intermediaries. Commission staff
understands that all currently registered funds have already entered
into such agreements with their intermediaries. Funds enter into new
relationships with intermediaries from time to time, however, which
requires them to enter into new information sharing agreements.
Commission staff understands that, in general, funds enter into
information-sharing agreement when they initially establish a
relationship with an intermediary, which is typically executed as an
addendum to the distribution agreement. Commission staff estimates that
there are approximately 6911 open-end fund series currently in
operation (excluding money market funds and ETFs). However, the
Commission staff understands that most shareholder information
agreements are entered into by the fund group (a group of funds with a
common investment adviser), and estimates that there are currently 669
currently active fund groups.\6\ Commission staff estimates that, on
average, each active fund group enters into relationships with
approximately 3 new intermediaries each year. Commission staff
understands that funds generally use a standard information sharing
agreement, drafted by the fund or an outside entity, and modifies that
agreement according to the requirements of each intermediary.
Commission staff estimates that negotiating the terms and entering into
an information sharing agreement takes a total of approximately 4 hours
of attorney time per intermediary (representing 2.5 hours of fund
attorney time and 1.5 hours of intermediary attorney time).
Accordingly, Commission staff estimates that each existing fund group
expends 12 hours each year \7\ to enter into new information sharing
agreements, and all existing fund groups incur a total of 8028
hours.\8\
---------------------------------------------------------------------------
\6\ ICI, 2011 Investment Company Fact Book at Fig 1.7 (2011)
(https://www.ici.org/stats/latest/2011_factbook.pdf).
\7\ This estimate is based on the following calculation: (4
hours x 3 new intermediaries = 12 hours).
\8\ This estimate is based on the following calculation: (12
hours x 669 fund groups = 8028 hours).
---------------------------------------------------------------------------
In addition, newly created funds advised by new entrants
(effectively new fund groups) must enter into information sharing
agreements with all of their financial intermediaries. Commission staff
estimates that there are approximately 40 new funds or fund groups that
form each year that will have to enter into information sharing
agreements with each of their intermediaries.\9\ Commission staff
estimates that funds and fund groups formed by new advisers typically
have relationships with significantly fewer intermediaries than
existing fund groups, and estimates that new fund groups will typically
enter into approximately 100 information sharing agreements with their
intermediaries when they begin operations.\10\ As discussed previously,
Commission staff estimates that it takes approximately 4 hours of
attorney time per intermediary to enter into information sharing
agreements. Therefore, Commission staff estimates that each newly
formed fund group will incur 400 hours of attorney time,\11\ and all
newly formed fund groups will incur a total of 16,000 hours to enter
into information sharing agreements with their intermediaries.\12\
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\9\ ICI, 2011 Investment Company Fact Book at Fig 1.7 (2011)
(https://www.ici.org/stats/latest/2011_factbook.pdf).
\10\ Commission staff understands that funds generally use a
standard information sharing agreement, drafted by the fund or an
outside entity, and then modifies that agreement to according the
requirements of each intermediary.
\11\ This estimate is based on the following calculation: (4
hours x 100 intermediaries = 400 hours).
\12\ This estimate is based on the following calculation: (40
fund groups x 400 hours = 16,000 hours).
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Rule 22c-2(a)(3) requires funds to maintain records of all
information sharing agreements for 6 years in an easily accessible
place. Commission staff estimates that there are approximately 6911
open-end fund series currently in operation (excluding money market
funds and ETFs). However, the Commission staff anticipates that most
shareholder information agreements will be stored at the fund group
level and estimates that there are currently approximately 669 fund
groups. Commission staff understands that information-sharing
agreements are generally included as addendums to distribution
agreements between funds and their intermediaries, and that these
agreements would be stored as required by the rule as a matter of
ordinary business practice. Therefore, Commission staff estimates that
maintaining records of information sharing agreements requires
approximately 10 minutes of time spent by a general clerk per fund,
each year. Accordingly, Commission staff estimates that all funds will
incur approximately 112 hours \13\ in complying with the recordkeeping
requirement of rule 22c-2(a)(3).
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\13\ This estimate is based on the following calculation: (10
minutes x 669 fund groups = 6690 minutes); (6690 minutes/60 = 112
hours).
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Therefore, Commission staff estimates that to comply with the
information sharing agreement requirements of rule 22c-2(a)(1) and (3),
it requires a total of 24,140 hours.\14\
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\14\ This estimate is based on the following calculation: (8028
hours + 16,000 hours + 112 hours = 24,140 hours).
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The Commission staff estimates that on average, each fund group
requests shareholder information once a week, and gives instructions
regarding the restriction of shareholder trades every day, for a total
of 417 responses related
[[Page 70519]]
to information sharing systems per fund group each year, and a total
278,973 responses for all fund groups annually.\15\ In addition, the
staff estimates that funds make 117 responses related to board
determinations, 2007 responses related to new intermediaries of
existing fund groups, 4000 responses related to new fund group
information sharing agreements, and 669 responses related to
recordkeeping, for a total of 6793 responses related to the other
requirements of rule 22c-2. Therefore, the Commission staff estimates
that the total number of responses is 285,766 (278,973 + 6793 =
285,766). The Commission staff estimates that the total hour burden for
rule 22c-2 is 25,661 hours.\16\
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\15\ This estimate is based on the following calculations: (52 +
365 = 417); (417 x 669 fund groups = 278,973).
\16\ This estimate is based on the following calculation: (1521
hours (board determination) + 24,140 hours (information sharing
agreements) = 25,661 total hours).
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Rule 22c-2 requires funds to enter into information sharing
agreements with their intermediaries that enable funds to, upon request
(i) be provided certain information regarding shareholders and their
trades that are held through a financial intermediary or an indirect
intermediary, and (ii) require the intermediary to execute instructions
from the fund restricting or prohibiting further purchases or exchanges
by shareholders that violate the fund's frequent trading policies. As a
result of this requirement, some funds and intermediaries have had to
develop and maintain information sharing, monitoring, and order
execution systems (collectively ``information sharing systems''). In
general, costs related to these information-sharing systems are borne
at the fund group level.
The Commission understands that all currently operating funds and
intermediaries have either developed information systems themselves or
purchased them from third parties. However, these funds and
intermediaries also incur certain ongoing costs related to these
systems' maintenance and operation. The Commission staff understands
that various organizations have developed, enhancements to their
systems that allow funds and intermediaries to share the information
required by the rule without developing or maintaining systems of their
own. Other organizations have developed ``22c-2 solution'' systems that
funds may lease. The Commission staff understands that most funds and
intermediaries use these outside systems. In general, the staff
estimates that the typical charges involved in operating and
maintaining information sharing systems average 25 cents for every 100
account transactions requested. These systems generally also provide
analytics, spreadsheets, and other tools designed to enable funds to
analyze the data presented, as well as communication tools to process
fund instructions regarding the restrictions and prohibitions they may
request. Commission staff estimates that the costs of developing,
maintaining and operating information systems for funds and
intermediaries that do not use outside provider's systems is comparable
to the costs charged by outside providers.\17\ The Commission staff
estimates that, on average, each fund group requests information for
100,000 transactions each week, incurring costs of $250 weekly, or
$13,000 a year.\18\ In addition, the Commission staff estimates that
funds pay access fees to use these information sharing systems (or
comparable internal costs) of approximately $30,000 each year. The
Commission staff therefore estimates that a fund group would typically
incur approximately $43,000 in costs each year related to the operation
and maintenance of information sharing systems required by rule 22c-2.
The Commission staff has previously estimated that there are
approximately 669 fund groups currently active, and therefore estimates
that all fund groups incur a total of $28,767,000 in ongoing costs each
year related to maintaining and operating information sharing
systems.\19\
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\17\ We include the burden for funds that develop and operate
these information sharing systems internally rather than purchasing
them from third parties as a cost rather than as an hourly burden
because Commission staff understands that, even when developing
these systems themselves, funds generally either use independent
contractors or hire new personnel, and thereby incur this burden as
a cost, not an hourly expenditure.
\18\ This estimate is based on the following calculations:
(100,000 transaction requests x 0.0025[cent] = $250); ($250 x 52
weeks = $13,000).
\19\ This estimate is based on the following calculation: (669
fund groups x $43,000 = $28,767,000).
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In addition, newly formed funds and fund groups advised by advisers
who are new entrants would also need to incur certain additional costs
related to the initial development or purchase of these information-
sharing systems. Commission staff estimates that it requires
approximately $100,000 to purchase or develop and implement such an
information sharing system for the first time. Commission staff has
previously estimated that approximately 40 funds or fund groups are
formed each year managed by new advisers, and therefore estimates that
all these funds would incur total costs of approximately
$4,000,000.\20\ Therefore the staff estimates that the total costs
related to rule 22c-2 would be approximately $32,767,000 ($28,767,000 +
$4,000,000 = $32,767,000).
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\20\ This estimate is based on the following estimate: ($100,000
x 40 new fund groups = $4,000,000).
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Responses provided to the Commission will be accorded the same
level of confidentiality accorded to other responses provided to the
Commission in the context of its examination and oversight program.
Responses provided in the context of the Commission's examination and
oversight program are generally kept confidential. Complying with the
information collections of rule 22c-2 is mandatory for funds that
redeem their shares within 7 days of purchase. An agency may not
conduct or sponsor, and a person is not required to respond to a
collection of information unless it displays a currently valid control
number.
Written comments are invited on: (a) Whether the proposed
collection of information is necessary for the proper performance of
the functions of the agency, including whether the information will
have practical utility; (b) the accuracy of the agency's estimate of
the burden of the collection of information; (c) ways to enhance the
quality, utility, and clarity of the information collected; and (d)
ways to minimize the burden of the collection of information on
respondents, including through the use of automated collection
techniques or other forms of information technology. Consideration will
be given to comments and suggestions submitted in writing within 60
days of this publication.
Please direct your written comments to Thomas Bayer, Director/Chief
Information Officer, Securities and Exchange Commission, C/O Remi
Pavlik-Simon, 6432 General Green Way, Alexandria, VA 22312; or send an
email to: PRA_Mailbox@sec.gov.
Dated: November 7, 2011.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2011-29253 Filed 11-10-11; 8:45 am]
BILLING CODE 8011-01-P