In response to Investment Company Act Rule 22c-2, BISYS developed a complete technology, compliance and service solution to help fund boards meet the anticipated compliance deadline of October 16, 2006. The Rule is designed to help mutual funds combat the market timing and frequent trading abuses that were identified over the past several years.

"22c-2 represents the most challenging and potentially cost-draining compliance requirement for fund companies that we've seen in recent years," said Fred Naddaff, president, BISYS Fund Services. "There are several facets of compliance, such as transaction detail management, that are not resident in existing transfer agent or portfolio systems. Additional burdens include the administration and negotiation of shareholder information agreements with intermediaries; market timing monitoring on direct accounts; and the reports and communications with intermediaries, the board of directors, and chief compliance officers. Though technology is a major component, it doesn’t solve a mutual fund's total 22c-2 compliance obligation. Since July 2005, we've been investing significant resources, leveraging our legal, regulatory and compliance expertise, as well as our technology partners, to design a cost-effective solution that encompasses the full scope of support," he said. "We are very proud to unveil the culmination of this diligent thought leadership, the BISYS 22c-2 Solution."

Available to clients who employ BISYS as a transfer agent and distributor, the BISYS 22c-2 Solution includes:

• Shareholder information agreement negotiations and execution
• Tracking and monitoring technology
• Trade compliance
• Ongoing analysis of account-level transaction data
• Reports tailored to the needs of the fund, boards, and CCOs
• Management of trade exceptions

BISYS has been an active participant, along with numerous investment companies and broker dealers, in several working groups over the past several months, including the Investment Company Institute (ICI), and Depository Trust & Clearing Corporation (DTCC). Under the guidance of Bruce Treff, executive vice president and general counsel for BISYS Fund Services, BISYS is helping clients to remain abreast of Rule developments and understand the Rule's practical application and requirements. According to Mr. Treff, "Rule 22c-2 poses major challenges to the mutual fund industry that require creative and collaborative initiatives to address the Rule's requirements. The BISYS 22c-2 Solution is an innovative full-service solution that enables our clients, who may be struggling with the demands of the mandate, to cost-effectively outsource the burdens of compliance. BISYS, on our clients' behalf, is closely monitoring the proposed amendments to Rule 22c-2 and will make modifications, as appropriate, to our solution. BISYS' clients can continue to focus on their core competencies: managing and distributing investments."