Mutual Funds Should Consider Deferring Form 24F-2 Filings in Light of Substantial Decrease in SEC Registration Fee Rate

Securities registration fee rates for mutual funds registered under the Investment Company Act of 1940 (the “1940 Act”) will be decreasing nearly 10%, effective October 1, 2014.  Mutual fund registration fees are calculated based on the rate that is in effect on the date of their annual fee filing on Form 24F-2.  Pursuant to Rule 24f-2 under the 1940 Act, a mutual fund is required to file a Form 24F-2 accompanied by the registration fee within 90 days after its fiscal year.  The fee rate in effect at the time of filing Form 24F-2 applies to all securities sold during the fiscal year.  Accordingly, mutual funds that, by virtue of the timing of their fiscal year end, are in a position to defer the payment of registration fees (in particular, funds with fiscal years ending in July or August that might ordinarily make an early filing in September)  should consider making Form 24F-2 filings on or after October 1, 2014.  Form 24F-2 filings submitted to the SEC before 5:30 p.m. ET on Tuesday, September 30, 2014 will be subject to the current fee rate of $128.80 per million dollars.  Filings submitted after that time will be subject to the new fee rate of $116.20 per million dollars.

This article relates specifically to mutual fund filers.  Other public companies should also consider whether they can achieve cost savings by deferring an upcoming filing.

Additional information on the fee rate increase is available on the SEC website at


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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