Reed Smith Client Alerts

On Sept. 27, 2006, the SEC adopted amendments to provisions of rule 22c-2 relating to "shareholder information agreements," and extended the dates by which affected funds must come into compliance with those provisions. Release No. IC-27504 ("Release"), available at http://www.sec.gov/rules/final/2006/ic-27504.pdf. Highlights of the Release are summarized below:

Dates: The "effective date" of the amendments will be 60 days after the Release is published in the Federal Register (publication likely during the week of Oct. 2, 2006). The SEC extended the "compliance dates" for the shareholder information agreement provisions of rule 22c-2 as follows. Affected funds have until April 16, 2007 to enter into "shareholder information agreements" with their "intermediaries." The SEC also extended, until Oct. 16, 2007, the date by which funds must be able to request and promptly receive shareholder identity and transaction information pursuant to shareholder information agreements.

Note: The SEC did not propose an extension of the compliance date for the provision of the rule that requires a fund's board to consider the adoption of a redemption fee policy [section 22c-2(a)(1)]. The compliance date for that provision remains Oct. 16, 2006.

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