From: Craig Barefoot
Good morning. Having scanned the proposed 25 step Proposed Distribution Plan for Aim Advisors, I am concerned that Step 15 on pages 23 and 24 of the Proposed Distribution Plan appears to potentially eliminate people, who were participants in a 401(k) retirement plan during the affected period and invested in the affected funds but who subsequently took a distribution of the assets from the plan, from receiving a pro rata distribution of the rightfully owed funds.
Also having been affected by Invesco funds during this period, I notice the Invesco Funds Group, Inc. Proposed Distribution Plan has a Certification Form (Page 34) that apparently may be submitted to attest to having held affected funds during the affected period. But, Step 16 (pages 24 and 25) of this proposal also gives discretion to the plan fiduciaries of Retirement Plans on who will receive the rightfully owed funds.
It seems prudent to me that all participants in the affected funds during the affected period should receive a pro rata distribution of the rightfully owed funds, regardless of their current participation status in the affected retirement plans.
Craig Barefoot, CEBS