A Jan. 30 article in Ignites reports on the industry reaction to a no-action letter recently issued by the SEC staff that clarifies that brokers (as opposed to dealers) may impose their own commissions on sales of so-called “clean shares” of registered investment companies, provided that the shares do not themselves impose sales charges or distribution fees. Investment management partner David Sullivan (Boston) is quoted in the piece, noting that although it would appear permissible for funds to charge other than distribution-related fees on clean shares, such as service and sub-transfer agency fees, the no-action letter is “silent” in this regard.
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