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Topics in Mutual Fund Transfer Agency and Revenue Sharing

This study relates to the overall concern that mutual fund payments of sub-accounting fees to broker/dealers for sub-transfer agency, administration, sub-accounting, and other shareholder services may improperly include distribution related services. The topics begin with a review of the basic elements of traditional mutual fund transfer agency. Next, the work of transfer agents and sub-transfer agents in processing fund transactions is discussed, including actual and potential problems with sub-transfer agency fees. A broker/dealer transparently discusses its fund services, including distribution, shareholder servicing, administration, marketing, and revenue sharing. Another broker/dealer discusses networking fees, omnibus fees, revenue sharing, and non-cash compensation in providing sub-transfer agency services. Next, follows a lengthy discussion of broker/dealer individual networked accounts and omnibus accounts in servicing fund shareholder accounts. Another broker/dealer succinctly describes networking and omnibus fees as they use them, followed by a discussion of broker/dealer individual networked accounts (and types) and omnibus accounts in servicing fund shareholder accounts. It is then discussed how funds and funds engaged in 401(k) pension plans both likely often use management fees to facilitate brokerage operations through opaque revenue sharing payments. Finally, the implications of prohibition of directed brokerage that led to fund revenue sharing and its several implications are discussed.