Vermont Adopts New Fees for Notice Filings, Securities Registrations, and Agents

The Vermont Division of Securities and Retail Franchising changed the following fees, effective July 1, 2008:

1. Notice filings. For offerings by investment companies under Section 18(b)(2) of the Securities Act of 1933 and for registrations of securities, the fee is now a flat $600. The old fee was $1.00 for each $1,000 of the aggregate amount of the offering of the securities to be sold in Vermont for which the issuer is seeking to perfect a notice filing under this section, with minimum and maximum fees of $400 and $1,250, respectively.

2. For offerings under Section 18(b)(4)(D) of the Securities Act of 1933--Rule 506 offerings--the fee is now a flat $600. The old fee was $1.00 for each $1,000 of the aggregate amount of the offering of the securities to be sold in Vermont for which the issuer is seeking to perfect a notice filing under this section, with minimum and maximum fees of $400 and $1,250, respectively.

IMPORTANT NOTE ON RULE 506: Even with the 7/1/2008 effectiveness of the $600 fee, Vermont still DOES NOT require a notice filing for Rule 506 offerings. HOWEVER, Securities Examiner John Reese in Vermont at jreese@bishca.state.vt.us has informed me 8/26/2008 that the Vermont Securities Staff is presently working on a 506 Rule to be adopted in a few months that will reinstate the notice filing on Form D, the Consent to Service of Process on Form U-2 and implement the $600 fee.

3. Agent registration fees. The registration fee for agents is $60, up from $55. However, the registration fee for investment adviser representatives remains at $55.