CMFI Comment Letter on Proposed SEC Transfer Agent Rules

The SEC issued a Concept Release on December 31, 2015, with regulatory proposals to modernize its transfer agent rules: https://www.gpo.gov/fdsys/pkg/FR-2015-12-31/pdf/2015-32755.pdf

 

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 number of regulatory and prospectus compliance problems for mutual funds and their investment advisers. 

 

For more than a decade, CMFI has advocated that the most efficient and cost-effective method to provide full transparency within omnibus accounts is for the SEC to amend its Rule 22c-2, to permit funds to receive investor identity and transaction information from intermediaries on a daily basis, as fund purchase and redemption orders are processed.

 

Click here to review CMFI's comment letter on this subject: https://www.sec.gov/comments/s7-27-15/s72715-50.pdf