December 11, 2011
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AMHC has engaged Phoenix Advisory Partners a division of American Stock Transfer and Trust LLC.to prepare a study on proxy solicitaionb costs for MHC. The study will sample proprietary data in order to gauge the solicitation cost per member for proxies to approve MHC waiver of dividends. phoenix did not include in its estimates legal and accounting and employee expenses. Neither did it weigh the loss in productivity or impact on depositor confidence.
AMHC obtains study by RP Financial which weighs the proxy solicitations costs estimated by Phoenix Advisory Partners as a percentage of dividends waivedRP Financial using the data prepared by Phoenix Advisory partners has compared the minimum costs of solicitation with the amount of dividends in calculation the cost to the MHC of each dollar of dividend waived.
AMHC submits cost studies to Federal Reserve Board staff.
The AMHC has submitted the Phoenix and RP Finnacial studies to the Federal reserve Board staff. The studies taken together demonstrate the unreasonable burden the cost of solicitation would place on MHCs. The staff will have to weigh whether the Reg MM requirement is a rwsonable one in view of the studies conclusion.