Submission for OMB Review; Comment Request, 2573-2575 [2012-781]
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Federal Register / Vol. 77, No. 11 / Wednesday, January 18, 2012 / Notices
POSTAL SERVICE
International Product Change—Global
Plus 1C and 2C Negotiated Service
Agreements
Postal ServiceTM.
ACTION: Notice.
AGENCY:
The Postal Service hereby
gives notice of its filing a request with
the Postal Regulatory Commission to
add Global Plus 1C and 2C Negotiated
Service Agreements to the Competitive
Products List.
DATES: January 18, 2012.
FOR FURTHER INFORMATION CONTACT:
Margaret M. Falwell, (202) 268–2576.
SUPPLEMENTARY INFORMATION: The
United States Postal Service® hereby
gives notice that, pursuant to 39 U.S.C.
3642, on December 30, 2011, and
January 4, 2012, it filed with the Postal
Regulatory Commission, Requests of
United States Postal Service to Add
Global Plus 1C and 2C Negotiated
Service Agreements to the Competitive
Products List, and Notices of Filing Two
Functionally Equivalent Agreements
and Applications for Non-Public
Treatment of Materials Filed Under Seal
for each filing. Documents are available
at https://www.prc.gov, Docket Nos.
MC2012–5, MC2012–6, CP2012–10,
CP2012–11, CP2012–12 and CP2012–13.
SUMMARY:
B. J. Meadows III,
Attorney, Legal Strategy.
[FR Doc. 2012–766 Filed 1–17–12; 8:45 am]
BILLING CODE 7710–12–P
SECURITIES AND EXCHANGE
COMMISSION
Submission for OMB Review;
Comment Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of Investor
Education and Advocacy,
Washington, DC 20549–0213.
tkelley on DSK3SPTVN1PROD with NOTICES
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’’) has submitted to the
Office of Management and Budget a
request for extension of the previously
approved collection of information
discussed below.
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
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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.
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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2573
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
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
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).
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18JAN1
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Federal Register / Vol. 77, No. 11 / Wednesday, January 18, 2012 / Notices
tkelley on DSK3SPTVN1PROD with NOTICES
the total time spent for all funds on this
process is 1,521 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
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 6,911 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
8,028 hours.8
In addition, newly created funds
advised by new entrants (effectively
new fund groups) must enter into
5 This calculation is based on the following
estimate: (13 hours × 117 funds = 1,521 hours).
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 = 8,028
hours).
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Jkt 226001
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
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 6,911 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
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 × 100 intermediaries = 400
hours).
12 This estimate is based on the following
calculation: (40 fund groups × 400 hours = 16,000
hours).
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Fmt 4703
Sfmt 4703
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
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, 2,007
responses related to new intermediaries
of existing fund groups, 4,000 responses
related to new fund group information
sharing agreements, and 669 responses
related to recordkeeping, for a total of
6,793 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 + 6,793 = 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
13 This estimate is based on the following
calculation: (10 minutes × 669 fund groups = 6,690
minutes); (6,690 minutes/60 = 112 hours).
14 This estimate is based on the following
calculation: (8,028 hours + 16,000 hours + 112
hours = 24,140 hours).
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: (1,521 hours (board determination) +
24,140 hours (information sharing agreements) =
25,661 total hours).
E:\FR\FM\18JAN1.SGM
18JAN1
Federal Register / Vol. 77, No. 11 / Wednesday, January 18, 2012 / Notices
tkelley on DSK3SPTVN1PROD with NOTICES
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
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).
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16:07 Jan 17, 2012
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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
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.
The public may view the background
documentation for this information
collection at the following Web site,
www.reginfo.gov. Comments should be
directed to: (i) Desk Officer for the
Securities and Exchange Commission,
Office of Information and Regulatory
Affairs, Office of Management and
Budget, Room 10102, New Executive
Office Building, Washington, DC 20503,
or by sending an email to:
Shagufta_Ahmed@omb.eop.gov; and (ii)
Thomas Bayer, Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 6432 General Green Way
Alexandria, VA 22312 or send an email
to: PRA_Mailbox@sec.gov. Comments
must be submitted to OMB within 30
days of this notice.
19 This estimate is based on the following
calculation: (669 fund groups × $43,000 =
$28,767,000).
20 This estimate is based on the following
estimate: ($100,000 × 40 new fund groups =
$4,000,000).
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2575
Dated: January 11, 2012.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–781 Filed 1–17–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Submission for OMB Review;
Comment Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of Investor
Education and Advocacy,
Washington, DC 20549–0213.
Extension:
Rule 17Ad–6 and 17Ad–7; SEC File No.
270–151; OMB Control No. 3235–0291.
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
(‘‘Commission’’) has submitted to the
Office of Management and Budget
(‘‘OMB’’) a request for approval of
extension of the existing collection of
information provided for in the
following rules: Rule 17Ad–6 (17 CFR
240.17Ad–6) and Rule 17Ad–7 (17 CFR
240.17Ad–7) under the Securities
Exchange Act of 1934 (15 U.S.C. 78a et
seq.) (‘‘Exchange Act’’).
Rule 17Ad–6 under the Exchange Act
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 under the Exchange Act
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 transfer agents to
monitor and keep control over their own
performance and for the Commission to
E:\FR\FM\18JAN1.SGM
18JAN1
Agencies
[Federal Register Volume 77, Number 11 (Wednesday, January 18, 2012)]
[Notices]
[Pages 2573-2575]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-781]
=======================================================================
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
Submission for OMB Review; 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'') has submitted to the Office of Management and
Budget a request for extension of the previously approved collection of
information discussed below.
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 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
[[Page 2574]]
the total time spent for all funds on this process is 1,521 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 = 1,521 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 6,911 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 8,028
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 = 8,028 hours).
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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 6,911
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 = 6,690 minutes); (6,690 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: (8,028
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 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, 2,007 responses related to
new intermediaries of existing fund groups, 4,000 responses related to
new fund group information sharing agreements, and 669 responses
related to recordkeeping, for a total of 6,793 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 +
6,793 = 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: (1,521
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
[[Page 2575]]
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\
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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.
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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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\18\ This estimate is based on the following calculations:
(100,000 transaction requests x $0.0025 = $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.
The public may view the background documentation for this
information collection at the following Web site, www.reginfo.gov.
Comments should be directed to: (i) Desk Officer for the Securities and
Exchange Commission, Office of Information and Regulatory Affairs,
Office of Management and Budget, Room 10102, New Executive Office
Building, Washington, DC 20503, or by sending an email to: Shagufta_Ahmed@omb.eop.gov; and (ii) 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. Comments must be submitted to OMB within 30 days of
this notice.
Dated: January 11, 2012.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-781 Filed 1-17-12; 8:45 am]
BILLING CODE 8011-01-P