Fund Directions quoted The Gemini Companies’ CEO, Andrew Rogers, in its article titled, “When Transfer Agent Fees get the 15(c) Treatment.” The article discusses how the recent SEC attention on transfer agencies has put the way mutual fund boards look at their relationships with TAs and the fees they charge in the forefront.

“Boards have different styles that work for them,” according to Andrew Rogers, CEO at Gemini Companies, a fund administration, accounting and transfer agency services provider. Rogers also serves as an interested trustee for the Northern Lights Trust funds board of directors, for which Gemini is considered a related party. He explained that the Northern Lights board requires Gemini to undergo a detailed assessment on all services and fees, similar to the 15(c) process for reviewing advisory fees. “It’s just a best practice,” according to Rogers. “Adopting 15(c)-like measures is very prudent for the board in overseeing various vendors.”

Even within the same fund family, there is a range of practices, according to Rogers. “All of our series trusts do not have the same process. Every board has their own style.” As such, Rogers said a regulatory framework that allows boards to exercise individual business judgement, rather than a prescriptive rule book formalizing the TA fee review process, makes the most sense.