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On September 1, 2011, CMFI submitted a comment letter to the Municipal Securities Rulemaking Board (MSRB) about Section 529 College Savings Plans.
The purpose of this comment letter is to inform the MSRB about a new recordkeeping practice that is being promoted by large broker-dealers to increase the fees that they can charge for services rendered to Section 529 Plans. This recordkeeping practice--called omnibus accounting--has recently been implemented for the Virginia College Savings Plan. And discussions are underway to expand the use of this recordkeeping practice to other State 529 Plans.
In its comment letter, CMFI recommends that the MSRB expand its requirements for broker-dealer fee disclosures and consider competitive bidding of broker-dealer recordkeeping contracts.
This comment letter can be accessed in the Documents tab of the Issue Page labeled Section 529 College Savings Plans.