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SEC Issues Long-awaited Distribution and Sub-accounting Guidance

On Jan. 6, 2016, the staff of the SEC’s Division of Investment Management released long-awaited guidance on mutual fund payments to intermediaries for services to omnibus and networked shareholder accounts.

The guidance reflects the IM staff’s views on a range of payments to financial intermediaries for non-distribution-related services, including sub-transfer agent, administration, sub-accounting and other shareholder servicing fees (the staff call these, collectively, the “sub-accounting fees”).

The guidance reaffirms that directors bear a substantial responsibility in approving these arrangements, expands the factors that boards should consider and identifies practices that should prompt greater board scrutiny …

If you have any questions or need additional information about this alert, please feel free to contact the authors below or any one of your Kramer Levin attorney contacts.
Alexandra K. Alberstadt Aviva L. Grossman

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