Adapting to changes in notice filing fees charged by states is a mainstream challenge for blue sky administrators. In 2016 alone, we distributed four (4) Compliance Bulletins to our clients, informing them that Alaska, Hawaii, South Dakota, and Vermont were making changes to their notice filing fees.
When changes are made to notice filing fees, in addition to simply posting a broadcast announcement on our secure client portal; we provide projected estimates of the potential financial impact for our clients. Understanding the financial impact helps make it possible for us to identify proactive action our clients can take to minimize the impact to their bottom line.
Consider the example of the State of Hawaii.
On November 30, 2016, we announced that we had noticed that Hawaii’s ten-year tradition of reducing filing fees had come to an end. In fact, Hawaii would instead be doubling their initial and renewal filing fees, effective with the start of the new year. Our announcement included an offer to analyze the potential financial impact to those clients with funds registered for sale in the Aloha State.
With the goal of helping our clients minimize the financial impact of this change, we also offered early filing, in advance of the January 1, 2017 fee increase, to the 25 clients with filings that expired in January or February. Sixty-eight percent (68%) of those clients took advantage of this opportunity, replying with comments like, “Thanks for the heads up on this. Why would we NOT do it?” and “Please proceed. Want to take advantage of savings. Thanks.” With the go-ahead from 17 clients, we processed renewal registrations for 295 portfolios, saving these clients a total of nearly $7,500 in notice filing fees.
In the grand scheme of things, it may not appear to be a significant amount of money, but it is to our clients and their investors. This same strategy, when extrapolated for state registration fee changes occurring multiple times a year, has the potential to offer savings that could make a difference to a fund’s bottom line.