Submission for OMB Review; Comment Request, 71464-71466 [2014-28309]
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71464
Federal Register / Vol. 79, No. 231 / Tuesday, December 2, 2014 / Notices
Please direct your written comments
to: Pamela Dyson, Acting Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 100 F Street NE., Washington,
DC 20549, or send an email to: PRA_
Mailbox@sec.gov.
Dated: November 25, 2014.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–28305 Filed 12–1–14; 8:45 am]
BILLING CODE 8011–01–P
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) Pamela
Dyson, Acting Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 100 F Street NE., Washington,
DC 20549 or by sending an email to
PRA_Mailbox@sec.gov. Comments must
be submitted within 30 days of this
notice.
SECURITIES AND EXCHANGE
COMMISSION
Dated: November 25, 2014.
Kevin M. O’Neill,
Deputy Secretary.
Submission for OMB Review;
Comment Request
[FR Doc. 2014–28308 Filed 12–1–14; 8:45 am]
BILLING CODE 8011–01–P
Upon Written Request, Copies Available
From: U.S. Securities and Exchange
Commission, Office of FOIA Services,
Washington, DC 20549–2736.
rljohnson on DSK3VPTVN1PROD with NOTICES
Extension:
Rule 15c1–5, SEC File No. 270–422, OMB
Control No. 3235–0471.
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
(‘‘PRA’’) (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 previously approved
collection of information provided for in
Rule 15c1–5 (17 CFR 240.15c1–5) under
the Securities Exchange Act of 1934 (15
U.S.C. 78a et seq.).
Rule 15c1–5 states that any brokerdealer controlled by, controlling, or
under common control with the issuer
of a security that the broker-dealer is
trying to sell to or buy from a customer
must give the customer written
notification disclosing the control
relationship at or before completion of
the transaction. The Commission
estimates that 223 respondents collect
information annually under Rule 15c1–
5 and that each respondent would
spend approximately 10 hours per year
collecting this information (2,230 hours
in aggregate). There is no retention
period requirement under Rule 15c1–5.
This Rule does not involve the
collection of confidential information.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
under the PRA unless it displays a
currently valid OMB control number.
The public may view 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,
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15:30 Dec 01, 2014
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SECURITIES AND EXCHANGE
COMMISSION
Submission for OMB Review;
Comment Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE., Washington, DC
20549–2736.
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) 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 open-end 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
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Sfmt 4703
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
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
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. 79, No. 231 / Tuesday, December 2, 2014 / Notices
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 2 hours of the
board’s time, as a whole, (at a rate of
$4000 per hour) 4 to approve a
redemption fee or make the required
determination on behalf of all series of
the fund. In addition, Commission staff
estimates that it takes compliance
personnel of the fund (at a rate of $64
per hour) 5 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
compliance counsel of the fund (at a
rate of $334 per hour) 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
13 hours 6 at a cost of $9514.7 As a
result, Commission staff estimates that
the total time spent for all funds on this
process is 884 hours at a cost of
$646,952.8
rljohnson on DSK3VPTVN1PROD with NOTICES
B. Information Sharing Agreements
Rule 22c–2(a)(2) requires a fund to
enter into information-sharing
3 Unless otherwise stated, estimates throughout
this analysis are derived from a survey of funds and
conversations with fund representatives.
4 The estimate of $4000 per hour for the board’s
time as a whole is based on conversations with
representatives of funds and their legal counsel.
5 Unless otherwise stated, all cost estimates for
personnel time are derived from SIFMA’s
Management & Professional Earnings in the
Securities Industry 2013, modified to account for an
1800-hour work-year and multiplied by 5.35 to
account for bonuses, firm size, employee benefits,
and overhead.
6 This calculation is based on the following
estimates: (2 hours of board time + 3 hours of
internal compliance counsel time + 8 hours of
compliance clerk time = 13 hours).
7 This calculation is based on the following
estimates: ($8000 ($4000 board time × 2 hours =
$8000) + $512 ($64 compliance time × 8 hours =
$512) + $1002 ($334 × 3 hours attorney time =
$1002) = $9514).
8 This calculation is based on the following
estimates: (13 hours × 68 funds = 884 hours); ($9514
× 68 funds = $646,952).
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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. 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
801 currently active fund groups.9
Commission staff estimates that, on
average, each active fund group enters
into relationships with 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 4 hours of attorney time (at a
rate of $380) per intermediary
(representing 2.5 hours of fund attorney
time and 1.5 hours of intermediary
attorney time). Accordingly,
Commission staff estimates that it takes
12 hours at a cost of $4560 each year 10
to enter into new information sharing
agreements, and all existing market
participants incur a total of 9612 hours
at a cost of $3,652,560.11
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 58 new fund groups that form each
year that will have to enter into
information sharing agreements with
each of their intermediaries.12
Commission staff estimates that fund
9 ICI, 2014 Investment Company Fact Book at Fig
1.7 (2014) (https://www.ici.org/pdf/2014_
factbook.pdf).
10 This estimate is based on the following
calculations: (4 hours × 3 new intermediaries = 12
hours); (12 hours × $380 = $4560).
11 This estimate is based on the following
calculations: (12 hours × 801 fund groups = 9612
hours); (9612 hours × $380 = $3,652,560).
12 ICI, 2014 Investment Company Fact Book at Fig
1.7 (2014) (https://www.ici.org/pdf/2014_
factbook.pdf).
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Fmt 4703
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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 100
information sharing agreements with
their intermediaries when they begin
operations.13 As discussed previously,
Commission staff estimates that it takes
4 hours of attorney time (at a rate of
$380) 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 at a
cost of $152,000,14 and all newly formed
fund groups will incur a total of 23,200
hours at a cost of $8,816,000 to enter
into information sharing agreements
with their intermediaries.15
Rule 22c–2(a)(3) requires funds to
maintain records of all informationsharing agreements for 6 years in an
easily accessible place. Commission
staff understands that most shareholder
information agreements are stored at the
fund group level and estimates that
there are currently 801 fund groups.16
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 informationsharing agreements requires 10 minutes
of time spent by a general clerk (at a rate
of $57) 17 per fund, each year.
Accordingly, Commission staff
estimates that all funds will incur
133.50 hours at a cost of $7609.50 18 in
complying with the recordkeeping
requirement of rule 22c–2(a)(3).
Therefore, Commission staff estimates
that to comply with the information
13 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 according to the
requirements of each intermediary.
14 This estimate is based on the following
calculations: (4 hours × 100 intermediaries = 400
hours); (400 hours × $380 = $152,000).
15 This estimate is based on the following
calculations: (58 fund groups × 400 hours = 23,200
hours) ($380 × 23,200 = $8,816,000).
16 ICI, 2014 Investment Company Fact Book at Fig
1.7 (2014) (https://www.ici.org/pdf/2014_
factbook.pdf).
17 $57 hour figure for a general clerk is derived
from SIFMA’s Office Salaries in the Securities
Industry 2013 modified to account for an 1800-hour
work-year and multiplied by 2.93 to account for
bonuses, firm size, employee benefits, and
overhead.
18 This estimate is based on the following
calculations: (10 minutes × 801 fund groups = 8010
minutes); (8010 minutes/60 = 133.5 hours); (133.5
hours × $57 = $7609.50).
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Federal Register / Vol. 79, No. 231 / Tuesday, December 2, 2014 / Notices
rljohnson on DSK3VPTVN1PROD with NOTICES
sharing agreement requirements of rule
22c–2(a)(2) and (3), it requires a total of
32,945.5 hours at a cost of
$12,476,169.50.19
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 334,017
responses for all fund groups
annually.20 In addition, as described
above, the staff estimates that funds
make 68 responses related to board
determinations, 2403 responses related
to new intermediaries of existing fund
groups, 5800 responses related to new
fund group information sharing
agreements, and 801 responses related
to recordkeeping, for a total of 9072
responses related to the other
requirements of rule 22c–2. Therefore,
the Commission staff estimates that the
total number of responses is 343,164
(334,017 + 9147 = 343,164).
The Commission staff estimates that
the total hour burden for rule 22c–2 is
33,829.5 hours at a cost of
$13,123,121.50.21 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,
19 This estimate is based on the following
calculations: (9612 hours + 23,200 hours + 133.5
hours = 32,945.5 hours); ($3,652,560 + $8,816,000
+ $7609.50 = $12,476,169.50).
20 This estimate is based on the following
calculations: (52 + 365 = 417); (417 × 801 fund
groups = 334,017).
21 This estimate is based on the following
calculations: (884 hours (board determination) +
32,945.5 hours (information sharing agreements) =
33,829.5 total hours); ($12,476,169.50 + $646,952 =
$13,123,121.50).
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15:30 Dec 01, 2014
Jkt 235001
or by sending an email to: Shagufta_
Ahmed@omb.eop.gov; and (ii) Pamela
Dyson, Acting Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 100 F Street NE., Washington,
DC 20549 or send an email to: PRA_
Mailbox@sec.gov. Comments must be
submitted to OMB within 30 days of
this notice.
Dated: November 25, 2014.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–28309 Filed 12–1–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31359; 812–14390
Banc of America Mortgage Securities,
Inc., et al.; Notice of Application and
Temporary Order
November 25, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
AGENCY:
Applicants have received a
temporary order (the ‘‘Temporary
Order’’) exempting them from section
9(a) of the Act, with respect to
injunctions entered against Bank of
America, N.A. (‘‘BANA’’), Merrill
Lynch, Pierce, Fenner & Smith
Incorporated (‘‘Merrill Lynch’’), and
Banc of America Mortgage Securities,
Inc. (‘‘BOAMS,’’ and, together with
BANA and Merrill Lynch, the
‘‘Respondents’’) on November 25, 2014
by the United States District Court for
the Western District of North Carolina
(the ‘‘District Court’’) until the
Commission takes final action on an
application for a permanent order (the
‘‘Permanent Order,’’ and with the
Temporary Order, the ‘‘Orders’’).
Applicants also have applied for a
Permanent Order.
Applicants: BofA Advisors, LLC
(‘‘BoA Advisors’’), BofA Distributors,
Inc. (‘‘BoA Distributors’’), KECALP Inc.
(‘‘KECALP’’), Merrill Lynch Ventures,
LLC (‘‘Ventures’’), Merrill Lynch Global
Private Equity, Inc. (‘‘MLGPE’’), and
Merrill Lynch Alternative Investments
LLC (‘‘MLAI’’) (each, an ‘‘Applicant’’
and collectively, the ‘‘Applicants’’), and
solely for purposes of agreeing to
condition 3 of the application, the
Respondents.
DATES: Filing Date: The application was
filed on November 25, 2014.
SUMMARY:
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Hearing or Notification of Hearing: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on December 22, 2014, and
should be accompanied by proof of
service on applicants, in the form of an
affidavit or, for lawyers, a certificate of
service. Pursuant to rule 0–5 under the
Act, hearing requests should state the
nature of the writer’s interest, any facts
bearing upon the desirability of a
hearing on the matter, the reason for the
request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090;
Applicants: BOAMS, 21 North Tryon
Street, Charlotte, NC 28255; BANA and
Merrill Lynch, Bank of America Tower,
One Bryant Park, New York, NY 10036;
BoA Advisors and BoA Distributors, 100
Federal Street, Boston, MA 02110;
KECALP and Ventures, 135 South
LaSalle Street, Chicago, IL 60604;
MLGPE, 135 South La Salle Street, Suite
811, Chicago, IL 60603; and MLAI, 4
World Financial Center, 250 Vesey
Street, 11th Floor, New York, NY 10080.
FOR FURTHER INFORMATION CONTACT:
David J. Marcinkus, Senior Counsel, at
202–551–6882 or Mary Kay Frech,
Branch Chief, at 202–551–6821
(Division of Investment Management,
Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and
summary of the application. The
complete application may be obtained
via the Commission’s Web site by
searching for the file number, or for an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm, or by calling (202) 551–
8090.
Applicants’ Representations
1. Bank of America Corporation
(‘‘BAC’’), a corporation organized under
the laws of Delaware, is a publicly
traded company headquartered in
Charlotte, North Carolina. As noted
below, each of the Respondents and
each of the Applicants is a direct or
indirect wholly-owned subsidiary of
BAC. BANA is a nationally chartered
banking association headquartered in
Charlotte, North Carolina that conducts
retail, trust and commercial banking
operations. BANA is an indirect wholly-
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Agencies
[Federal Register Volume 79, Number 231 (Tuesday, December 2, 2014)]
[Notices]
[Pages 71464-71466]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-28309]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
Submission for OMB Review; Comment Request
Upon Written Request, Copies Available From: Securities and Exchange
Commission, Office of FOIA Services, 100 F Street NE., Washington, DC
20549-2736.
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) 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 open-end 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
[[Page 71465]]
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 2 hours of the board's time, as a whole,
(at a rate of $4000 per hour) \4\ to approve a redemption fee or make
the required determination on behalf of all series of the fund. In
addition, Commission staff estimates that it takes compliance personnel
of the fund (at a rate of $64 per hour) \5\ 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
compliance counsel of the fund (at a rate of $334 per hour) 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 13 hours \6\ at a cost
of $9514.\7\ As a result, Commission staff estimates that the total
time spent for all funds on this process is 884 hours at a cost of
$646,952.\8\
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\3\ Unless otherwise stated, estimates throughout this analysis
are derived from a survey of funds and conversations with fund
representatives.
\4\ The estimate of $4000 per hour for the board's time as a
whole is based on conversations with representatives of funds and
their legal counsel.
\5\ Unless otherwise stated, all cost estimates for personnel
time are derived from SIFMA's Management & Professional Earnings in
the Securities Industry 2013, modified to account for an 1800-hour
work-year and multiplied by 5.35 to account for bonuses, firm size,
employee benefits, and overhead.
\6\ This calculation is based on the following estimates: (2
hours of board time + 3 hours of internal compliance counsel time +
8 hours of compliance clerk time = 13 hours).
\7\ This calculation is based on the following estimates: ($8000
($4000 board time x 2 hours = $8000) + $512 ($64 compliance time x 8
hours = $512) + $1002 ($334 x 3 hours attorney time = $1002) =
$9514).
\8\ This calculation is based on the following estimates: (13
hours x 68 funds = 884 hours); ($9514 x 68 funds = $646,952).
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B. Information Sharing Agreements
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. 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 801 currently active
fund groups.\9\ Commission staff estimates that, on average, each
active fund group enters into relationships with 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 4 hours of attorney time (at a rate of $380)
per intermediary (representing 2.5 hours of fund attorney time and 1.5
hours of intermediary attorney time). Accordingly, Commission staff
estimates that it takes 12 hours at a cost of $4560 each year \10\ to
enter into new information sharing agreements, and all existing market
participants incur a total of 9612 hours at a cost of $3,652,560.\11\
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\9\ ICI, 2014 Investment Company Fact Book at Fig 1.7 (2014)
(https://www.ici.org/pdf/2014_factbook.pdf).
\10\ This estimate is based on the following calculations: (4
hours x 3 new intermediaries = 12 hours); (12 hours x $380 = $4560).
\11\ This estimate is based on the following calculations: (12
hours x 801 fund groups = 9612 hours); (9612 hours x $380 =
$3,652,560).
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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 58 new fund groups that form each year that
will have to enter into information sharing agreements with each of
their intermediaries.\12\ Commission staff estimates that 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 100 information sharing
agreements with their intermediaries when they begin operations.\13\ As
discussed previously, Commission staff estimates that it takes 4 hours
of attorney time (at a rate of $380) 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
at a cost of $152,000,\14\ and all newly formed fund groups will incur
a total of 23,200 hours at a cost of $8,816,000 to enter into
information sharing agreements with their intermediaries.\15\
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\12\ ICI, 2014 Investment Company Fact Book at Fig 1.7 (2014)
(https://www.ici.org/pdf/2014_factbook.pdf).
\13\ 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 according to the
requirements of each intermediary.
\14\ This estimate is based on the following calculations: (4
hours x 100 intermediaries = 400 hours); (400 hours x $380 =
$152,000).
\15\ This estimate is based on the following calculations: (58
fund groups x 400 hours = 23,200 hours) ($380 x 23,200 =
$8,816,000).
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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 understands that most shareholder information
agreements are stored at the fund group level and estimates that there
are currently 801 fund groups.\16\ 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 10 minutes of time spent by a general clerk (at a rate of $57)
\17\ per fund, each year. Accordingly, Commission staff estimates that
all funds will incur 133.50 hours at a cost of $7609.50 \18\ in
complying with the recordkeeping requirement of rule 22c-2(a)(3).
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\16\ ICI, 2014 Investment Company Fact Book at Fig 1.7 (2014)
(https://www.ici.org/pdf/2014_factbook.pdf).
\17\ $57 hour figure for a general clerk is derived from SIFMA's
Office Salaries in the Securities Industry 2013 modified to account
for an 1800-hour work-year and multiplied by 2.93 to account for
bonuses, firm size, employee benefits, and overhead.
\18\ This estimate is based on the following calculations: (10
minutes x 801 fund groups = 8010 minutes); (8010 minutes/60 = 133.5
hours); (133.5 hours x $57 = $7609.50).
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Therefore, Commission staff estimates that to comply with the
information
[[Page 71466]]
sharing agreement requirements of rule 22c-2(a)(2) and (3), it requires
a total of 32,945.5 hours at a cost of $12,476,169.50.\19\
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\19\ This estimate is based on the following calculations: (9612
hours + 23,200 hours + 133.5 hours = 32,945.5 hours); ($3,652,560 +
$8,816,000 + $7609.50 = $12,476,169.50).
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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 334,017 responses for all fund groups
annually.\20\ In addition, as described above, the staff estimates that
funds make 68 responses related to board determinations, 2403 responses
related to new intermediaries of existing fund groups, 5800 responses
related to new fund group information sharing agreements, and 801
responses related to recordkeeping, for a total of 9072 responses
related to the other requirements of rule 22c-2. Therefore, the
Commission staff estimates that the total number of responses is
343,164 (334,017 + 9147 = 343,164).
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\20\ This estimate is based on the following calculations: (52 +
365 = 417); (417 x 801 fund groups = 334,017).
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The Commission staff estimates that the total hour burden for rule
22c-2 is 33,829.5 hours at a cost of $13,123,121.50.\21\ 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.
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\21\ This estimate is based on the following calculations: (884
hours (board determination) + 32,945.5 hours (information sharing
agreements) = 33,829.5 total hours); ($12,476,169.50 + $646,952 =
$13,123,121.50).
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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) Pamela Dyson, Acting Director/
Chief Information Officer, Securities and Exchange Commission, c/o Remi
Pavlik-Simon, 100 F Street NE., Washington, DC 20549 or send an email
to: PRA_Mailbox@sec.gov. Comments must be submitted to OMB within 30
days of this notice.
Dated: November 25, 2014.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-28309 Filed 12-1-14; 8:45 am]
BILLING CODE 8011-01-P