Harlow Ridge Securities accepts mutual fund orders as the fund's authorized agent. A principal sees a purchase order time-stamped 4:12 p.m. Eastern that received that day's net asset value; the fund prices at 4:00 p.m. Eastern. What should the principal do?
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Answer: A
Have the order repriced at the next NAV computed after receipt and review the firm's cutoff controls: Correct. Rule 22c-1 requires forward pricing: an order is priced at the next NAV computed after receipt. An order received at 4:12 p.m. gets the next day's NAV; giving it the 4:00 p.m. price is late trading.
Let the price stand because the customer called before the market closed in his own time zone: Incorrect. Forward pricing runs from the fund's pricing time and the time the order was received, not the customer's local time.
Let the price stand because the fund had not yet published that day's NAV: Incorrect. Under Rule 22c-1 what matters is when the order was received relative to the 4:00 p.m. pricing time, not when the NAV was published.
Cancel the order and require the customer to resubmit it on the next business day: Incorrect. The order can be processed at the next computed NAV; cancelling it is unnecessary and does not address the control gap.
Under Rule 22c-1, fund shares are bought and redeemed at the NAV next computed after the order is received; post-cutoff orders receive the next day's price.