From: Richard F. Curcio
Our company, Integrity Investments, Inc., is the sole distributor of our proprietary money market mutual fund, The Valiant Fund, which is sold exclusively to institutional investors, primarily banks. The Fund has multiple classes with different 12-b1 payments made for shareholder servicing, a minimum investment of $1million and is sold on an application way basis to banks, savings institutions and investment companies who maintain omnibus accounts with The Fund.
We believe that our clients are extremely well qualified and should be exempt from the rule. Our management fee is capped at 20 basis points and the various 12-b1 fees are added to that depending on the class of shares chosen by the bank for its various types of customers. With the preponderance of new rules and regulations which have increased our cost of operation, there is absolutely no room for us to absorb the additional cost of implementing this rule for qualified investors such as banks, savings institutions, insurance companies and other investment companies.
While we are a small part of this universe, we have been able to compete successfully with the larger institutional money market funds by controlling our costs, and by providing superior service and competitive yields. Implementation of this rule without exemption for qualified institutional clients is overkill and would accomplish very little other than increasing the cost of doing business.
Very truly yours,