估算综合账户股息和资本收益支出（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. Estimating Omnibus Account Dividend and CapitalGains Disbursements Contents Introduction The mutual fund transfer agency landscape has evolved to the point where significant numbers of mutual fundshares are now held in intermediary-controlled omnibus accounts. ICI’s Broker-Dealer Advisory Committee OmnibusDistributions Task Force has developed the following definition ofomnibus accounts. Omnibus accountshold mutual fund shares that are registered with the mutual fund’s transfer agent inthe name of the financial intermediary. The intermediary maintains the underlying shareholder (beneficialowner) account information on its own subaccounting or retirement plan participant recordkeepingsystems1and reports share transactions to the fund on an aggregate basis. The intermediary or its agenthandles all communications and servicing of its customer accounts. The omnibus model offers certain operating efficiencies for the intermediary in servicing beneficial owners. However,as the underlying shareholders in an omnibus account do not directly interact with the mutual fund company and itstransfer agent, these parties may have limited to no knowledge or transparency about the underlying shareholders. One important operational area where this lack of transparency is especially notable for funds is when they areplanning for payment of dividend2and capital gains distributions. When a fund declares a dividend or capital gain,its investment manager must ensure that there is sufficient cash available for the fund to pay distributions toshareholders who have elected to receive proceeds in cash.3While the fund’s transfer agent can survey its books andrecords to determine shares eligible for distributions paid in cash versus reinvestment, there are limitations to thatapproach when certain omnibus accounts are considered. To assist fund and transfer agent personnel who may plan for and execute payment of dividend and capital gainsdistributions, the Investment Company Institute’s Broker-Dealer Advisory Committee (ICI BDAC) convened a workinggroup of members—funds, intermediaries, and service providers—to identify strategies to more effectively incorporateomnibus accounts into the preparation and management of dividend and capital gains distributions and payments.The working group’s goals are to educate asset managers, intermediaries, and service providers about various optionsavailable and to promote the intermediaries' adoption of resources that help to provide important beneficial ownertransparency to their fund counterparties. The paper highlights the use of solutions provided to the industry by theDepository Trust & Clearing Corporation (DTCC) Wealth Management Services (WMS) Mutual Fund Services business unitto facilitate efficient, high-volume distribution event processing between counterparties.4 Background Distribution Options and Beneficial Owner Accounts Each account maintained on the fund’s transfer agent system typically has one distribution option for dividends anda second for capital gains.5Options are established on account opening or maintained thereafter on the basis ofshareholder instruction. In the absence of explicit instructions, options are established by a default value specifiedin the fund’s prospectus. Most omnibus intermediaries elect to reinvest distribution proceeds into their omnibusaccounts, which is consistent with many fund default distribution payment options and—not surprisingly—howmany shareholders receive their distributions. An omnibus intermediary, like any shareholder, may elect to receivedistribution proceeds in other permissible payment options, including cash.6 Because the omnibus account represents the interests of multiple underlying shareholders, the dividend or capitalgains option elected on the omnibus account held by the fund’s transfer agent does not typically represent the actualelections made byallunderlying shareholders.7Instead, the omnibus intermediary holds this information on itsrecordkeeping system for underlying beneficial owners; details are not directly available to the fund’s transfer agent.Mutual fund companies and their transfer agents require additional transparency into the distribution elections madeby the underlying shareholders to most accurately estimate fund shares subject to payment of distribution proceeds incash or reinvested shares. Processing Distributions When a fund company declares a dividend or capital gain, it publishes the following attributes regarding the event: »Rec