Rule 22(c)2 Excessive Trading - recordkeeper's responsibilities

[SRP]

I am with a recordkeeper who uses a proprietary recordkeeping system.

We had anticipated that we would be required to develop an enhancement to our system to handle tracking of short-term trading ("round trips"), warning of participants approaching the fund's policy and ultimately temporarily blocking the participant from future trades if the policy has been violated.

However, the way that things seem to be panning out is that perhaps the fund company's are really retaining responsibility for such tracking/analysis.

The reason I say this is because our custodian (for our omnibus accounts) requires us to respond with summary and detail transaction data only upon request from a fund company. It is not clear to me if they will also expect us to have already blocked someone from a trade or if they will only ask us to block the participant from further trades for a period of time. Fortunately, we have not had any requests to date. Secondly, the prospectuses for many of the funds that I have checked indicate that in the case of an omnibus account there isn't a specific indication that the recordkeeper is obligated to track/warn/block as needed. One prospectus of a fund (that has an obnoxious short-term trading policy) indicated that the recordkeeper is expected to follow the policy "or some other reasonable alternative".

Our situation is that the custodian is the "intermediary" as far as is goes with the agreement with the fund company. In our situation if we do not respond within 4 days of the fund company's request for data then futher trading (as the recordkeeper remitting trades) in that specific fund may be halted by the fund company (except that we may be granted a short extension if necessary).

I am looking for feedback from other recordkeeper's as to how they are handling the SEC Rule 22©2 short-term trading requirements:

1 - Does your recordkeeping software fully handle the rules set per each fund company?

2 - Are you using the SPARK recommendation (or some other reasonable and consistent policy) regardless of the specifics of any given fund company's policy?

3 - Are you only responding upon the custodian's requirement to provide data per fund company requests?

Thanks in advance for your input.