MFP Gross Return Reinvestment (Sys Item 17)
As noted earlier, the reinvestment of expense adjustments is always done at month end. Eagle Performance supports only one assumption for when the adjustments occur, so it is not necessary to provide a system setting. However, the system includes one for the purpose of providing flexibility in the future (as necessary). The system default is M for monthly. No other frequencies are supported at this time.
MFP Gross Up Before Other Distributions (Sys Item 18)
There are two options for this setting, N (No) and Y (Yes). The default is N (No). This option is meant to control the share balance that is used when calculating the reinvestment of actual distribution activity. If the setting is N (No), the impact of both the expenses and distributions are calculated using the prior day's end-of-day share balance. If the setting is Y (Yes), the calculation first reinvests the expense accrual (which is calculated using the prior day's shares as noted above). Once the share balance has been increased by the expense, it reinvests the distributions. This has the effect of increasing the share balance used to calculate the reinvestment shares of the distribution.
Eagle could not find commentary from a governing body, stating that it is a requirement to reinvest expense adjustments prior to calculating the effect of actual distributions. Therefore, the system default for this setting is N (No). This means that the effects of both expenses and actual distribution activity (for the same day) are based on the same prior day share balance.
MFP Tax Adjustments (Sys Item 20)
There are two options for this setting, N (No) and Y (Yes). This option is meant to control whether or not the reinvestment shares from expense adjustments are subject to post-tax and post-liquidation processing. If the setting is N (No), and the dynamic mutual fund performance field is set to be a post-tax or post-liquidation field, the calculation does not tax the expense accrual amount. Nor does it track the cost basis and apply post-liquidation processing (it continues to tax adjust distribution activity). If the setting is Y (Yes) and the field is either post-tax or post liquidation, the expense accrual is taxed as income prior to reinvestment. The reinvestment shares are then tracked just like a distribution and treated the same in terms of post-liquidation processing. The default for this setting is N (No).
The SEC post-tax and post-liquidation requirements offer no specific requirements or guidance with respect to tax adjustments for gross of expense returns. At this time, Eagle Performance considers there to be a distinction between the reinvestment shares from actual distribution activity of a fund, versus that which comes from expense adjustment activity. Conceptually, one represents actual fund based activity while the other is merely a mechanism to estimate a grossed up return. In the absence of guidance from any governing body, Eagle Performance designed this option to allow each client to decide for themselves whether or not expense shares are subject to post-tax processing. This setting only applies to shares from expense adjustment activity. When processing a post-tax or post-liquidation field, if this setting is NO, you do not tax the expense activity, but you do tax-adjust actual distribution activity.
Add Comment