Rule 22C-2 Agreement

In cases where the shares held are not fully disclosed and the board of directors of a fund decides to introduce a repurchase tax, a fund company must enter into a written agreement with any direct financial intermediary (or “first” that holds shares on behalf of other investors. While most industry professionals are considering resuming the language of the model agreement recently issued by the Investment Company Institute (ICI) and the Securities Industry Association (SIA), each agreement should contain the following: the term “intermediation” refers to a “financial institution” within the meaning of SEC Rule 22c-2. Rule 22c-2 requires an investment fund to enter into a shareholder information pact with any financial intermediary that gives orders to the fund, including those holding shares via omnibus accounts, whereby the financial intermediary agrees to provide the investment fund, upon request, certain information relating to the identity of the shareholders and transactions. No more than 16 October 2007, an investment fund must be able to request and obtain immediate information on the identity and transaction information of shareholders in connection with shareholder information agreements with its financial intermediaries. Introduction As we all know, fund companies and financial intermediaries will do a great deal of work across the industry to prepare for compliance with the dry redemption fee rule (Rule 22c-2), which is due to be implemented on October 16, 2006. Here we look at the rule, what it is and how FundsNetwork`s approach benefits all fund companies. (5) The shareholder information contract refers to a written agreement approved by a financial intermediary: potential problem areas/complexity throughout the sector: fund companies and intermediaries preparing to comply with Rule 22 quater-2, there are many complex issues that need to be considered and addressed. Some of these issues include: Receiving orders through the New York Stock Exchange (“NYSE”) at a NYSE opening date (or any other period set by the Fund) is considered to be the receipt of the Fund for the net inventory value of that day, to the extent that it is authorized by Rule 22c-1 of the Investment Company Act of 1940 (“40 Act”) and the agreement between Price Services and the Intermediary. On compliance with Rule 22c-2 of Law 40. As a preview, fund companies can anticipate improvements to the Real-Time Trade Activity (RTTA) tool available on FundsNetwork.com. We are still hearing positive feedback on our RTTA reports and plan to build on this by expanding search functions and adding more robust features that significantly improve a fund company`s oversight process. We will provide more details on future RTTA updates as we move closer to the 22c-2 rule implementation date. Overview Rule 22c-2 allows an investment fund to collect a withdrawal tax of no more than 2% of the amount collected, in order to allow a fund to recover some of its direct and indirect costs resulting from short-term trading strategies such as the market date.

As you know, we have requested your participation in our 22c-2 rule investigation. Responses to this survey are used only to determine the most pleasant conditions for all fund companies and to facilitate the contracting process. For those who have completed the survey, we appreciate your participation and your feedback has proven invaluable. However, the reuse and reuse of information received from consumers under these exceptions is limited. An investment fund may only use and disclose the identity and transactional information of shareholders it receives from a financial institution in order to carry out transactions in accordance with the activity under which the information was received.2 The SEC states that: unless the confidentiality policy of a financial intermediary specifies that the financial intermediary shares non-public personal data with investment funds for marketing purposes.