As the mutual fund industry wrestles with the details of SEC's Rule 22c-2, it's important that we as an industry don't miss a significant opportunity. Rule 22c-2 presents the industry with the ability - and arguably, the obligation - to ensure that trades within omnibus accounts are held not only to a fund's short-term trading rules, but to all fund prospectus policies and procedures.

In enabling fund companies to request and receive omnibus account data from their intermediaries, 22c-2 gives funds a tool to oversee shareholder account detail that was previously inaccessible to them. Narrowly interpreted, 22c-2 addresses short-term trading. We at DST Systems view the 22c-2 opportunity more broadly. It is our position that, with this new transparency, funds should provide the same level of oversight of omnibus accounts that they provide for fully disclosed accounts.

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