On September 26, 2006, the SEC voted to adopt proposed amendments to Rule 22c-2, the redemption fee rule (the “Rule”), under the Investment Company Act of 1940. Originally adopted in 2005, the Rule requires most mutual funds to enter into written shareholder information-sharing agreements with intermediaries (e.g., broker-dealers and retirement plan administrators) that use omnibus accounts to hold shares on behalf of other investors. Under such agreements, the intermediaries must provide certain investor information to the funds upon request, so that the funds can monitor market timing and other abusive transactions. The Rule also requires fund boards to consider whether a redemption fee policy is appropriate for their funds.


This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.