[Opinion]

4/11/2006: SPARK Institute Comment Letter to SEC on Mutual Fund Redemption Fees, Rule 22c-2 Amendment (PDF) (SPARK Institute)

12 pages. Excerpt: The Rule should not be narrowly focused on redemption fees as the preferred approach for controlling or preventing abusive trading but should also consider and authorize other approaches ... (e.g., trade blocking and round trip limits).... Rule 22c-2 should be revised to allow mutual fund companies to authorize retirement plan intermediaries to monitor for market timing and excessive trading ... as an alternative to the cumbersome and costly information sharing requirements.