共同基金股份类别转换：可能性矩阵（pdf）

Copyright © 2020 Investment Company Institute. All rights reserved. The content contained in this document is proprietary property of ICI and should not be reproduced or disseminated without ICI’s priorconsent. The information contained in this document should be used solely for purposes of assisting firms in making independent andunilateral decisions relevant to their respective business operations. It is not intended to be, and should not be construed as, legal advice. Mutual Fund Share Class Conversions:A Matrix of Possibilities Contents Introduction Many asset managers distribute their mutual fund portfolios in a “multi-class” structure. Each class is distinguishedby unique shareholder eligibility requirements, services offered, and combinations of fees and expenses for funddistribution. These options allow shareholders to select the best combination of features to meet their investmentobjectives. Fund documents such as prospectuses and statements of additional information (SAI) outline the availableshare class(es) for any given portfolio, disclosing applicable fees and expenses and describing shareholder eligibilityand operating characteristics.1 Converting mutual fund shares from one share class to another within the same mutual fund portfolio is not anew concept; however, it is one that has garnered additional attention in recent years. Shareholders’ investingcircumstances change over time, and what was once a suitable share class may no longer be the most appropriate foran investor because of changes in eligibility based on asset growth or other factors. For instance, investors may changehow they receive and pay for investment advice, moving from a share class where commissions are paid on eachtransaction to an advisory program with different share classes where fees for advice are calculated based on assetsunder management. Mutual fund share class conversions within the same mutual fund portfolio adjust the shares outstanding of the twoaffected share classes without altering the size of the mutual fund portfolio. The conversion transaction adjusts theshares held by accounts on the fund transfer agent system in each share class. When applicable, intermediaries mustalso post the share class conversion in beneficial owner accounts tracked by omnibus subaccounting or retirementplan participant recordkeeping systems.2 Conversions may occur at the initiation of the fund or an intermediary as the result of either a “coordinated” or a “non-coordinated” event corresponding to a business objective: 1.Coordinated eventsreflect a scheduled or planned activity at the fund or intermediary. Examples may include anintermediary’s scheduled conversion into a new share class structure or prospectus-driven periodic conversionfrom one share class subject to a contingent deferred sales charge (CDSC)3to a share class that is free from CDSC(e.g., Class B or C to Class A). 2.Non-coordinated eventsare often initiated by an intermediary’s financial adviser, are ad hoc in nature, or pertainto an individual or a small group of shareholders. Neither intermediary nor mutual fund operations groupstypically receive advance notification that activity is to occur. Operationally, the mutual fund industry has identified multiple approaches to complete share class conversions,also referred to as share class exchanges, for both coordinated and non-coordinated events. The approach used isoften determined by the capabilities of the submitting organization’s underlying recordkeeping system, the businessobjective, and common industry practices.4Parties will typically pursue the most automated transaction methodavailable to them in hopes of recognizing maximum operational efficiency and risk-reduction benefits, althoughdefault/preferred approaches often differ between funds and intermediaries. To assist those who may need to process mutual fund share class conversions, the Investment Company Institute’sBroker-Dealer Advisory Committee (ICI BDAC) convened a task force of members—funds, intermediaries, and serviceproviders—to consolidate the various broadly available automated approaches that are commonly used to completemutual fund share class conversions. The task force’s goal is to educate asset managers, intermediaries, and serviceproviders about the options available and to highlight each option’s benefits, risks, and barriers to adoption. The ShareClass Conversion Matrix described in this paper is the result of the task force’s work. About the Share Class Conversion Matrix The matrix on the following pages has been divided into two main sections, distinguished between coordinatedand non-coordinated event types. Each event type is presented within the matrix one or more times, based on thealternatives available to process a share class conversion. Considerations »The ICI BDAC is committed to promoting operational efficiencies for all industry participants. For this reason,the task force limited the scope of automated tradi