March 20, 2006
The Sungard Relius Administration recordkeeping system is used by over 1200 third party administration firms, financial institutions, insurance companies, actuaries, and accounting professionals for the purpose of administering qualified retirement plans. Our clients trade on a multitude of trade platforms in both omnibus and super omnibus modes. While our licensed users have direct relationships with dozens of first tier intermediaries (as defined in Rule 22c-2), we have formal relationships with only a few. Nonetheless, all of our clients and their first tier intermediaries will be reliant on our system to fulfill their requirements for compliance with 22c-2 and their shareholder information agreements with the funds.
We fully recognize the scope of our obligation to provide our clients and their intermediaries with the necessary tools to ensure complete and total compliance. As such, we have closely monitored the progress of the NSCC and ICI committee's development of the Standardized Data Reporting program and will be building logic within our recordkeeping system to comply with their file layouts and processing requirements. This project will entail considerable cost to our organization for development, system maintenance, and customer training and support.
As you are aware, the NSCC/ICI file layouts became final only within the last few days, and we can now begin work on development of the import of the fund data request and export of the required trade information from our recordkeeping system. A production implementation date of October 2006 is not a realistic timeframe given the recent finalization of the file layouts for the data exchange. The systems modifications needed to support the data exchange will require time for analysis, design, programming, certification, and implementation by our many clients. Since most of our financial institution clients are required to put new software installations into test beds for sixty (60) to ninety (90) days, and since the NSCC test window does not open for several more weeks, it is not reasonable to expect that software development firms can make all required changes within the next eight or ten weeks to fulfill the October deadline.
We respectfully ask the Securities and Exchange Commission to reconsider the deadline for implementation of Rule 22c-2 as regards the exchange of data for omnibus and super omnibus retirement plans and their recordkeeping systems. We fully intend to build the necessary systems to support Rule 22c-2, however the timeframe does not permit us to do so while following our normal SAS70 approved development protocols. Our goal is to provide a complete and reliable solution to the reporting requirements, however we must be afforded the necessary time to develop and distribute this solution to our large and diverse client base of retirement professionals, and our clients must in turn be allowed time to install and certify the system with their respective intermediaries.
Your consideration of this request is greatly appreciated.
Michele A. Coletti, QKA, CEBS, Fellow of the International Society of Certified Employee Benefit Specialists
Senior Business Analyst, Sungard Relius
Senior Vice President, Sungard Relius