It's the end of 2015, and most mutual funds are paying out their annual dividends, which I have enrolled in DRIPs (dividend reinvestment programs). Since a "DRIP" transaction is similar to purchasing shares of the fund, would a DRIP-purchase date be subject to a redemption fee restriction?
Often, mutual funds charge a redemption fee (typically if you sell a holding < 90 days after purchasing) to discourage short-term holdings of their fund (for good reasons of course!).
However, come 2016, I would like to rebalance my portfolio and much of the recent DRIP purchases that just kicked in make me wonder if they're subject to redemption fee penalties.
The only thing I could find about this in a Google search was an SEC document on Mutual Fund Redemption fees discussing Investor Initiated Transactions (page 26) from the year ~2005 stating (bold emphasis mine):
We are considering whether the rule should require that any redemption fee charged by a fund be limited to transactions initiated by investors. Under such an approach, redemption fees would not be assessed with respect to (i) shares purchased with reinvested dividends or other distributions [...]
However, I can't determine if this discussion-style document has any sort of actual legal bearing today. Can anyone comment or help me understand, say, if a mutual fund that just paid me $100 in dividends on December 30th, 2015, and has a 90-day redemption-fee of 2%, would exempt the fee for DRIP purchases if I turned around and sold my holdings in January of 2016 (less than 90 days)? Is it a fund-by-fund basis or is there a specific law restriction now in place (vis-a-vis the quoted document above)?
Thanks in advance for any tips and pointers!