On January 6, 2016, the US Securities and Exchange Commission (“SEC”) published a Guidance Update (the “Guidance”) concerning payments made by mutual funds to financial intermediaries that provide shareholder and recordkeeping services for investors in such funds. The Guidance is a product of a three-year sweep exam conducted by the SEC that studied these payments, which are typically classified as sub-transfer agent, administrative, sub-accounting and other shareholder servicing fees (collectively, “sub-accounting fees”). Background on the…