| Final Rule Requirements
| RR Donnelley Solution
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| Update summary section in the prospectus following the items and order required by the SEC rule |
1. Provide full-service composition: in-house composition account managers create and manage templates for style
2. Offer self-service composition: development teams create templates for style and content management all of the documents you create |
| Bookmark electronic versions of the statutory prospectus and SAI that are posted to the web |
3. Add bookmarks and links for e-delivery: we audit bookmarks and links to ensure they are working and in compliance according to the SEC rule |
| Summary section of the full (statutory) prospectus required to be tagged in XBRL beginning January 1, 2011 |
4. Perform in-house XBRL tagging: we will tag one fund in a series to create a tagging template as part of RR Donnelley's on-boarding program. Our internal version of the SEC viewer allows customers to view filing BEFORE submitting |
| File each Summary Prospectus as a separate 497K |
5. Complete EDGAR filing: filing management system has a process dashboard, armor plating and reporting capabilities to track form types and filing status |
| Print Summary Prospectus |
6. Print of Summary and statutory prospectuses: low cost offset print/ fold/ wafer seal production, plus flexibility to compare costs for formats of four-, six- and eight-page full-size and digest-size options available |
| Produce electronic versions of statutory prospectus, SAI, and Summary Prospectus with links between all three documents |
7. Offer three styles of linking: ability to add all required sets of links between electronic versions of documents that all comply with the SEC requirements
8. Add bookmarks and links for e-delivery: we audit bookmarks and links to ensure they are working and in compliance according to the SEC rule |
| An investor must be able to call a toll free number, or request through email, to obtain printed or electronic versions of statutory prospectus, SAI, annual and semi-annual shareholder reports, free of charge |
9. Offer full-service call center: receives on-going requests, via phone and email, for printed documents or electronic requests, as well as track call times, date/time of call requests, product type, and version for all calls |
| Provide printed or electronic version of statutory prospectus, SAI, annual and/or semi-annual shareholder reports to an investor upon request |
10. Deliver printed statutory prospectus (including all supplements), SAI and annual/semi-annual shareholder reports: fulfillment can be from pre-printed inventory or via on-demand print
11. E-deliver statutory prospectus, SAI, and annual/semi-annual shareholder reports: fulfillment via electronic delivery is upon request and can be for one-time delivery or ongoing delivery
- Tracking of transmission of requested documents and confirmation of receipt or "bounce-back"
- Process for handling transmission to invalid e-mails
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| If an investor has consented to receive the statutory prospectus electronically then the consent carries over to the Summary Prospectus |
12. Manage consent and web-presentation: Full regulatory e-delivery platform manages consent and web-presentation of both public and private documents, as well as e-delivery of mandated annual compliance documents - Prospectuses, shareholder reports, supplements and other notices or marketing communications. |
| Current, linked versions of the Summary Prospectus, statutory prospectus and SAI must be posted to the web. |
13. Provide web presentment: make electronic versions of documents available for a fund company's website, host direct PDFs from the fund companies or source documents from other URLs, or access third-party, branded documents from our 22,000+ prospectus repository |
| Investor requested documents must be delivered within three days of the request |
14. E-deliver statutory prospectus, SAI, annual/semi-annual shareholder reports: fulfillment of requests including all relevant supplements to be sent to investor within 3 days of the request via e-mail
15. Mail statutory prospectus, SAI, annual and semi-annual shareholder reports: digital print capabilities available
- Tracking of mail of requested documents
- Process for handling invalid addresses
16. Fulfill first dollar prospectus: although not addressed in the mandate, the delivery process for first dollar prospectus fulfillment will continue with regulatory-specific time frames |
| Mutual fund companies should be prepared for SEC audits of their participation and compliance with all of the requirements. |
17. Offer tracking of the "audit likely" areas in the summary prospectus process: reporting from beginning to end to show compliance with the SEC rule requirements
18. Supply performance reporting & audit preparation: complete, ongoing documentation of RR Donnelley's performance related to all aspects of the Summary prospects process that we manage |
| Analyze costs every cycle to identify areas to improve upon |
19. Provide cost reporting: Cost-tracking and reporting for ongoing process improvement |
| Review cycle processes and identify areas to improve upon |
20. Plan for next communication cycle: Consultation and recommendations for ongoing process improvements in planning future prospectus cycle updates |
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