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" ... These exams, which were a joint initiative of the Office of Compliance Inspections and Examinations and a number of other offices and divisions of the Commission, highlighted the need to clarify and update the existing guidance. They also raised questions as to whether, in some cases, a portion of fund-paid subaccounting fees may have been used to pay for activities that are primarily intended to result in the sale of mutual fund shares (“distribution” or “distribution-related activity”). ... "