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Proactively Minimizing the Impact of Fee Changes
September 4, 2024 by Kevin L. Caravella
Fund managers are already navigating a complex matrix of regulations across 53 jurisdictions. Regulations across jurisdictions are constantly changing with 13 rule changes taking place across 12 jurisdictions since 2017 alone. Changes are not always communicated directly to wealth and asset managers, which can make it difficult to respond efficiently.
Blue Sky regulators have the authority to change their fee structures at any time, to any price and with little notice. Changes in fee schedules might arise because of legislative changes, budgetary needs, operational costs and overall economic conditions. It’s an unpredictable risk and challenge asset managers are forced to respond to quickly to ensure they remain compliant while dealing with the financial impact on their bottom line.
A Sudden Regulatory Shift
A recent example of this occurred in the state of Vermont. SS&C Blue Sky was notified in mid-June 2024 by Vermont that Blue Sky fees for renewal notice filings were increasing from $1650 to $2025, a $375 increase, effective July 1, 2024.
SS&C Blue Sky Administration immediately conducted an impact analysis across all clients to understand the scope of the fee change. The analysis revealed that the changes would result in an increase of more than $2.5m across the entire client base.
Collaborating to Implement a Solution
SS&C Blue Sky Administration immediately contacted jurisdiction regulators in Vermont to discuss the changes, and the impact to our clients—the goal being to determine how we can reduce the $2.5m financial implications.
Renewal notice filings are typically processed within 60 days of the expiration of the current permit and, given the two-week notice provided by Vermont, SS&C Blue Sky Administration saw an opportunity to potentially expedite the renewal of permits expiring close to the time of the announcement.
SS&C partnered with the Vermont regulators and reached an agreement that any renewal notice filing for permits expiring between 7/1 – 8/31 could be renewed under the current $1650 rate if the notice filings were received before July 1.
Upon confirmation of this agreement with the regulators, SS&C quickly presented the impact analysis to clients to communicate the change, the impact, and the opportunity to expedite renewal notice filings in Vermont to take advantage of the current rate and reduce the financial impact on their firms.
SS&C then created, processed and coordinated funding to deliver approximately 600 renewal notice filings before July 1, resulting in a total savings of $343,500 across all clients.
Choosing a Proactive Partner
SS&C Blue Sky Administration prides itself on our consultative approach with both our clients and the jurisdictional regulators alike. Our proactive service enables us to deliver tangible results for our clients while always ensuring compliance. This is just one example of how we leverage our industry leadership to maximize savings for our clients in every way possible.
To learn more about our service and other real-life examples, read our "Blue Sky Administration" eBook.
Written by Kevin L. Caravella
Director of Regulatory Compliance