at typical 12b-1 fund growth rates for a fund to be able to achieve sufficient scale economies to offset 12b-1 fees. Finally, there is no evidence that funds with 12b-1 plans have lower deposit and redemption flow volatility, lower cash balances or higher returns. In all, the evidence demonstrates that 12b-1 plans are successful at attaining faster

Ex.(28)(m)(1) AMENDED AND RESTATED RULE 12b-1 PLAN . State Street Institutional Investment Trust . 1. The Trust.The State Street Institutional Investment Trust (the “Trust”) is an open-end management investment company registered as such under the Investment Company Act of 1940, as amended (the “1940 Act”), and organized as a series trust (each such series is …

The Questionnaire for Self-Reporting Advisers and Attachment linked to the Announcement require the adviser to provide specific data concerning the 12b-1 fees the investment adviser received, either directly or indirectly, including the amount of 12b-1 fees in excess of the lowest-cost share class available and the amount of ill-gotten gains ...

SMEAD FUNDS TRUST (the “Trust”) Rule 12b-1 Plan. The Plan (“Plan”) described below is adopted pursuant to the provisions of Rule 12b-1 (“Rule 12b-1”) under the Investment Company Act of 1940, as amended (the “1940 Act”), by the Board of Trustees (“Board” and the members individually, “Trustees”) of the Trust, including a majority of the Trustees who: (i) are not ...

NOW, THEREFORE, the Trust on behalf of the Funds hereby amends and adopts this Plan in accordance with Rule 12b-1 under the 1940 Act. 1. This Plan is adopted so as to allow the Trust to make payments as contemplated herein, in conjunction with the distribution of shares of each Fund (“Shares”). 2.

Rule 12b-1 prohibits mutual funds from engaging, directly or indirectly, in the financing of any activity which is primarily intended to result in the sale of fund shares except pursuant to a 12b-1 plan. 8 As noted in the 12b-1 Adopting Release, this prohibition applies not only to payments that are clearly identified as distribution fees, but also

” means the improperly disclosed 12b-1 Fees and/or Markups paid calculated in accordance with the Plan of Allocation. 23. “ Relevant Period ” is defined as follows: (a) For claims relating to Cetera Advisors: i. September 8, 2012 through December 31, 2016, inclusive, for conduct involving 12b-1 Fees. ii.

Exhibit 28(m)(4) CLASS T PLAN OF DISTRIBUTION PURSUANT TO RULE 12b-1. OF . GABELLI ESG FUND, INC. WHEREAS, GABELLI ESG FUND, INC., a Maryland Corporation (the “Fund”), engages in business as an open-end management investment company and is registered as such under the Investment Company Act of 1940, as amended (the “Act”);

A "Self-Reporting Adviser" is an adviser that received 12b-1 fees in connection with recommending, purchasing, or holding 12b-1 fee paying share classes for its advisory clients when a lower-cost share class of the same fund was available to those clients, and failed to disclose explicitly in its Form ADV the conflicts of interest associated ...

Feb 28, 2017 · The following Distribution (12b-1) and Services Plan (the “Plan”) has been adopted pursuant to Rule 12b-1 (the “Rule”) under the Investment Company Act of 1940, as amended (the “1940 Act”) by Matthews International Funds (d/b/a Matthews Asia Funds) (the “Trust”), with respect to the Investor Class Shares of each series of the ...