What action will ICMA-RC take against violators of the frequent trading policy?
Upon the first frequent trading violation of any fund, ICMA-RC will issue a courtesy letter to educate the investor on ICMA-RC’s frequent trading policy, and will provide detail of the violation(s) and what fund(s) it occurred. The second violation of any fund will result in a warning letter identifying the fund(s) with frequent trading violation(s), and the possible repercussions of another frequent trading violation of any fund. Upon the third violation of any fund, a restriction letter will be issued and transfers into that fund will be restricted for 180 days. If subsequent violations occur, another restriction letter will be issued and transfers into that fund may be restricted permanently. Sells are not restricted at any time.
