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05 January, 2017 - Niels Holch

This column was published by Fund Board Views on January 5, 2017.


Four areas of focus when overseeing distribution fees, practices


By Niels Holch, Coalition of Mutual Fund Investors


The Securities and Exchange Commission has been focused for some time now on mutual fund distribution fees and practices. The SEC conducted a number of sweep examinations over the past several...

21 October, 2016 - Niels Holch

The SEC is conducting a review of Rule 22c-2 and CMFI submitted a comment letter on October 20, 2016.  This SEC review is a requirement under the Regulatory Flexibility Act that all rulemakings be evaluated after 10 years.


Rule 22c-2 provides authority for mutual funds to charge redemption fees in order to discourage market timing in fund shares.  Excessive short-term trading harms long-term shareholders by diluting the value of their shares.  SEC investigations into market timing determined that it was relatively easy for arbitageurs to hide out...

06 September, 2016 - Niels Holch

Mutual fund directors face many new challenges overseeing disclosures and monitoring whether they are accurate, meaningful, complete and timely.


Over the past several years, the Securities and Exchange Commission has increased the disclosure requirements for cyber security, fair valuation, money market funds, derivatives, sub-transfer agent fees, fixed-income risks and changing market conditions. The SEC has also initiated enforcement cases involving inaccurate or inadequate disclosures, with sanctions being imposed on both...

18 August, 2016 - Niels Holch

CMFI wrote to the SEC Investor Advisory Committee on August 18, 2016, expressing support for the Committee's recent recommendation that the SEC explore ways to improve mutual fund cost disclosures.


Here is a link to the Investor Advisory Committee's recommendation of April 14, 2016: 


In its letter, CMFI...

15 April, 2016 - Niels Holch

The SEC issued a Concept Release on December 31, 2015, with regulatory proposals to modernize its transfer agent rules:


On April 15, 2016, CMFI submitted a comment letter on this Concept Release.


A substantial majority of mutual fund shares now reside within intermediary-controlled omnibus accounts and the lack of transparency into investor identities and transactions has resulted in a significant...

21 March, 2014 - Niels Holch

On March 20, 2014, the Coalition of Mutual Fund Investors (CMFI) filed a comment letter with the Securities and Exchange Commission (SEC), in response to a new rule change affecting Section 529 college savings plans.


Click here to review this CMFI comment letter:


17 September, 2013 - Niels Holch

Earlier today, the Coalition of Mutual Fund Investors (“CMFI”) filed a comment letter with the Securities and Exchange Commission (“SEC”) on the agency’s proposed rules governing money market funds.


In its letter, CMFI asserted that several of the SEC’s regulatory proposals—including the retail exemption concept and the imposition of redemption fees in a liquidity crisis—create the need to provide money market funds with transparency into omnibus accounts used by broker-dealers and other financial intermediaries.


04 April, 2013 - Niels Holch

The March issue of the publication iMoneyNet ( contains an excellent analysis of the obstacles that omnibus accounts create for money market fund reforms involving redemption restrictions, such as redemption fees and gates, as well as the minimum-balance-at risk proposal.


Click here to review this article:



21 January, 2013 - cmfi

On January 21, 2013, the Coalition of Mutual Fund Investors ("CMFI") sent a comment letter to the Financial Stability Oversight Council ("FSOC") on money market fund reforms.


The FSOC recently published a series of proposed recommendations regarding the regulatory framework for money market funds, to reduce the risk of a "run" on assets in a future financial crisis. These proposals include a floating Net Asset Value ("NAV"), a capital buffer, a minimum holdback requirement, standby redemption "gates," and standby redemption fees. Several of the FSOC regulatory proposals...

25 April, 2012 - Niels Holch

The March 30 decision by the 8th Circuit Court of Appeals in the Gallus advisory fee case was a relief for many in the mutual fund industry. The Court ruled in favor of Ameriprise Financial and this case is now essentially over. However, fund boards need to remain vigilant on excessive fee issues, as the SEC may be picking up where the plaintiff’s bar is leaving off.


In its decision in Gallus, the Court of Appeals determined that the advisory fee review process used by the Ameriprise fund board was “robust.” It also concluded that the lower court’s review of the disputed...