This year, mutual fund fee-related analysis and benchmarking, mandated under Rule 15(c) but also needed elsewhere (such as among funds with expense ratio caps), may require fund managers and trustees to go beyond traditional analytics using last year's fee data. Some of these concerns were elaborated in a recent 15(c) related commentary to fund trustees by Mr. Andrew Donohue, Director, SEC's Division of Investment Management, on January 13, 2009 suggesting that "fund directors will likely want to consider carefully additional information or issues that may not have been present in previous reviews" (read full text on http://www.sec.gov/news/speech/2009/spch011309ajd.htm).
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Avi Nachmany, Executive Vice President, Director of Research, Strategic Insight
Kevin Shine, Managing Director, Strategic Insight