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Home  > Business/Finance  >  Financial Services  >  Fund Management

Rule 22c-2, the SEC's Response to Market Timing: Implications for the Mutual Fund Industry

Published Date: August 2005
Published By: TowerGroup
Page Count: 16
Order Code: R301-904
 
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TowerGroup Take-Aways


Report Coverage


Background
Exhibit 1: Recent History of SEC Regulations Regarding Market Timing (2003-06)
An Omnibus Primer
Exhibit 2: With Omnibus Accounting, Only the Intermediary Knows the Shareholder (2005)
Exhibit 3: Allocation of US Mutual Fund Accounts by Recordkeeping Method (2005)

Components of Rule 22c-2
Omnibus Transparency
Voluntary Redemption Fees


Rule 22c-2 Exceptions and Open Issues
Exhibit 4: Superomnibus Approach: Multiple Intermediary Relationships (2005)
Clarification from the SEC Will Bring Relief


Implications of Rule 22c-2
Exhibit 5: US Mutual Funds' Phased Approach to Rule 22c-2

Phase 1A: Agreement Process


Phase 1B: Redemption Fee Policy


Phase 2: Transaction Monitoring
The Need for a Standard Data Feed
Transmission of Transaction Data
More Frequent Oversight
Corrective Action and Reporting


Options for Transaction Monitoring Technology
Exhibit 6: Analysis Tools for Mutual Funds to Supervise Frequent Trading (2005)
Analysis Tools by Top 3 Transfer Agency Software Providers
Third-Party Solutions
Frequent Trading Policies as an Alternative to Redemption Fees


Price Tag for Compliance with Rule 22c-2
Exhibit 7: Rule 22c-2 Costs to Mutual Funds: SEC Estimates vs. TowerGroup Estimates (2005-08)
Agreement Process
Redemption Fee Policy Preparation
Exhibit 8: Estimated Year 1 Costs of Rule 22c-2 Compliance: Redemption Fee Policy (2005)
Redemption Fee Implementation
Transaction Activity Monitoring


Summary
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