RegAlert1994-11-01
Added · Updated
SEC Division of Investment Management staff letter: Linsco/Private Ledger Corp.
The staff of the Division of Investment Management will not recommend enforcement action to the Commission under Section 22(d) of the Investment Company Act of 1940 if Linsco/Private Ledger Corp. charges its customers a support services fee for transactions in investment company securities while also receiving Rule 12b-1 fees from those investment companies. This relief applies because LPL acts as an agent for its customers in these transactions, meaning Section 22(d) restrictions do not apply to LPL's involvement. The support services fee is paid entirely to Pershing for clearing, custodial, and customer-level accounting services, while the Rule 12b-1 fees compensate LPL for administrative, trade processing, and educational services.
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i NOV 1~~4
p Our Ref. No. 94-333-CC
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Linsco/Private Ledger Corp.
DIVISION OF INVESTMNT MAAGEMENT File No. 801-10970
Your letter of June 6, 1994 requests our assurance that we would not recommend enforcement action to the Commission under
Section 22 (d) of the Investment Company Act of 1940 (" 1940 Act")
if Linsco/Private Ledger Corp. ("LPL") charges its customers a
support services fee for transactions in investment company
securities while also receiving Rule 12b-1 fees from those
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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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