https://www.sec.gov/Archives/edgar/data/1295908/000158064224002881/lebenthal_497.htm
497 1 lebenthal_497.htm 497
LEBENTHAL ULTRA SHORT TAX-FREE INCOME FUND
A Series of Centaur Mutual Funds Trust
Supplement dated May 29, 2024, to the Summary Prospectus, Statutory Prospectus and
Statement of Additional Information, each dated February 28, 2024
Effective immediately, the Lebenthal Ultra Short Tax-Free Income Fund (the “Fund”), a series of Centaur Mutual Funds Trust (the “Trust”), has terminated the public offering of its shares and will discontinue its operations effective July 10, 2024. Shares of the Fund are no longer available for purchase and, at the close of business on July 10, 2024, all outstanding shares of the Fund will be redeemed at net asset value (the “Transaction”).
The Board of Trustees of the Trust (the “Board”), at the recommendation of the Fund’s investment advisor, DCM Advisors, LLC (the “Adviser”), determined and approved by Written Consent of the Board on May 29, 2024 (the “Written Consent”), to discontinue the Fund’s operations based on, among other factors, the Advisor’s belief that it would be in the best interests of the Fund and its shareholders to discontinue the Fund’s operations. Through the date of the Transaction, the Advisor will continue to waive investment advisory fees and reimburse expenses of the Fund, if necessary, in order to maintain the Fund at its current expense limit, as specified in the Fund’s Prospectus.
Through the Written Consent, the Board directed that: (i) all of the Fund’s portfolio securities be liquidated in an orderly manner not later than July 10, 2024; and (ii) all outstanding shareholder accounts on July 10, 2024, be closed and the proceeds of each account be sent to the shareholder’s address of record or to such other address as directed by the shareholder, including special instructions that may be needed for Individual Retirement Accounts (“IRAs”) and qualified pension and profit sharing accounts. As a result of the Transaction, the Fund’s portfolio holdings will be reduced to cash or cash equivalent securities. Accordingly, going forward, shareholders should not expect the Fund to achieve its stated investment objectives. Any capital gains will be distributed as soon as practicable to shareholders and reinvested in additional Fund shares, unless you have requested payment in cash.
Shareholders may continue to freely redeem their shares on each business day prior to the Transaction. Procedures for redeeming your account, including reinvested distributions, are contained in the section “Redeeming Your Shares” in the Fund’s Prospectus. Any shareholders that have not redeemed their shares of the Fund prior to July 10, 2024, will have their shares automatically redeemed as of that date, with proceeds being sent to the address of record. If your Fund shares were purchased through a broker-dealer or other financial intermediary and are held in a brokerage or other investment account, redemption proceeds may be forwarded by the Fund directly to the broker-dealer or other financial intermediary for deposit into your brokerage or other investment account.
The Transaction will be considered for tax purposes a sale of Fund shares by shareholders, and shareholders should consult with their own tax advisors to ensure its proper treatment on their income tax returns.
IMPORTANT INFORMATION FOR RETIREMENT PLAN INVESTORS
Shareholders invested through an IRA or other tax-deferred account should consult the rules regarding the reinvestment of these assets. In order to avoid a potential tax issue, shareholders generally have 60 days from the date that proceeds are received to re-invest or “rollover” the proceeds in another IRA or qualified retirement account; otherwise the proceeds may be required to be included in the shareholder’s taxable income for the current tax year.
If you have any questions regarding the Fund, please call 1-888-484-5766.
Investors Should Retain this Supplement for Future Reference

https://www.sec.gov/Archives/edgar/data/225930/000174177324002468/c497.htm
497 1 c497.htm
6316 P2 05/24
TEMPLETON FUNDS
SUPPLEMENT DATED MAY 29, 2024
TO THE SUMMARY PROSPECTUS, PROSPECTUS AND
STATEMENT OF ADDITIONAL INFORMATION (“SAI”)
EACH DATED JANUARY 1, 2024, OF
TEMPLETON INTERNATIONAL CLIMATE CHANGE FUND (THE “FUND”)
On May 22, 2024, the Board of Trustees of Templeton Funds, on behalf of Templeton International Climate Change Fund (the “Fund”), approved a proposal to liquidate and dissolve the Fund. The liquidation is anticipated to occur on or about August 9, 2024 (Liquidation Date); however, the liquidation may occur sooner if at any time before the Liquidation Date there are no shares outstanding in the Fund. The liquidation may also be delayed if unforeseen circumstances arise.
At the close of market on July 2, 2024, the Fund will be closed to new investors, except as noted below. Existing investors who had an open and funded account on July 2, 2024 can continue to invest in the Fund through exchanges and additional purchases after such date. The following categories of investors may continue to open new accounts in the Fund after the close of market on July 2, 2024: (1) clients of discretionary investment allocation programs where such programs had investments in the Fund prior to the close of market on July 2, 2024, and (2) Employer Sponsored Retirement Plans or benefit plans and their participants where the Fund was available to participants prior to the close of market on July 2, 2024. The Fund will not accept any additional purchases after the close of market on or about August 7, 2024. The Fund reserves the right to change this policy at any time.
Shareholders of the Fund on the Liquidation Date will have their accounts liquidated and the proceeds will be delivered to them. For those shareholders with taxable accounts and for Federal, state and local income tax purposes: (a) any liquidation proceeds paid to such shareholder should generally be treated as received by such shareholder in exchange for the shareholder’s shares and the shareholder will therefore generally recognize a taxable gain or loss; (b) in connection with the liquidation, the Fund may declare taxable distributions of its income and/or capital gain; and (c) an exchange out of the Fund prior to the Liquidation Date may be considered a taxable transaction and such shareholders may recognize a gain or loss. Shareholders should consult
their tax advisers regarding the effect of the Fund’s liquidation in light of their individual circumstances. Participants in an Employer Sponsored Retirement Plan that is a Fund shareholder should consult with their plan sponsor for further information regarding the impact of the liquidation. In considering new purchases or exchanges, shareholders may want to consult with their financial advisors to consider their investment options.
Please retain this supplement for future reference.

BTW, I don't use RMD services at funds/brokerages. But I do subscribe to some for information only, not execution.
I calculate my own RMDs and take them as regular withdrawals. When RMDs apply, the 1st withdrawals from T-IRA or 401k/403b are assumed to be RMDs anyway.
I used to take RMDs early in January, but after the 2020 fiasco, I now take them in mid/late-year. This despite knowing that we won't see ad-hoc reversal of RMDs again in my lifetime.

From Barron's May 6, 2024,
Frequent changes in the RMD rules are confusing. For tax-deferred accounts (T-IRA, 401k, 403b), the RMD age is 73 now (was 72 in 2023, 70.5 in 2020) and it will remain so until 2033. The RMD amount depends on the yearend balances, age-related IRS factor, and other factors such as marital status, very young spouse, beneficiaries. The 1st RMD can be delayed to April 1 of the following year but beware of the tax impact of double RMDs then. The RMD can be postponed if working. (There is a special 55.0-59.5 rule that avoids 10% penalty for premature withdrawals from a current 401k/403b; not so for old 401k/403b or T-IRA). The RMDs from T-IRAs can be aggregated and taken from any one T-IRA, and it’s similar for 403b, but not for 401k. There are different rules for inherited accounts for spouses, nonspouses, trusts, and whether the deceased had started taking the RMDs. The QCDs are allowed from T-IRAs. The Roth IRAs no longer require RMDs. (R-IRA rules are simple in retirement if 5 years beyond Roth Conversions, but nightmarish otherwise.)

@shipwreckedandalone, the article had several good points.
Quote: "By highlighting the “full market cycle” as the right period for judgment, they’re reminding investors that over shorter spans within the cycle they’ll look,"
FD: is now the start of the market cycle? Is it a good choice to start in the middle?
Full market cycle also means you must stay in the fund for many years to get the benefit of this fund....and now we get to the second problem
Quote: "Since most investors have limited patience, most absolute value investors have limited careers."
FD: can you stay long term in this fund? probably not, Cinnamond never managed the same fund for 15-20 years. His record shows 5 and 6 years, he is already in his fifth year at PVCMX. Since the fund has so much cash, it's obvious Cinnamond can't find valuable stocks, he may quit soon. In 2016 he said "Mr. Cinnamond recommended return of capital to his investors, noting that the market was fundamentally hostile to his investment style and that he was unwilling to charge investors “equity fund prices” while sitting at 90% cash."
==========
Do I think this fund can serve a goal?
Absolutely, if you are a retiree who has enough and just needs 6-7% with lower SD, go for it. This is where I am, but I use bond funds for that and do my own timing going to cash. On the other hand, a fund like RSIIX may generate 6-7% with lower SD but you can own it for years. MM have been paying over 5% for months now.
How strong are you going to be in years when the fund is lagging badly...2021 PVCMX made 3.2% per M* same category made over 31%.
Another idea...use it instead of VWIAX. The problem again is the fact I can own VWIAX for the next 30 years.
Another idea...it can be a good choice for someone EXPLORE portion.
Trade it? not a bad idea, but if you are a good trader you can do better or you know when to use it.
Lastly, another problem is when many investors like to mention funds that have done well in the last several years and start using them when markets start to take off or avoid stocks for years.

I like PVCMX. Lets look at the entire picture since 5/1/2019: M* 5 star fund.
PVCMX CAGR 7.44% VIOO 7.86%
PVMCX MDraw -6.45% VIOO -42.37%
PVCMX SD 5.85% VIOO 26.92%
PVCMX Sharpe .86 VIOO .20
PVCMX Ulcer 1.28 VIOO 13.87
PVCMX achieved comparable upside with substantially less volatility and downside.
IJS metrics is similar to VIOO with less CAGR than PVCMX.
Read David's MFO review:
https://www.mutualfundobserver.com/2019/07/launch-alert-palm-valley-capital-fund-pvcmx/
Also see 9/2020 MFO update.
I am amazed adults cannot understand there is a different tool for different objectives.
Every person has a right to their own objective with their own tool with their own money.
There is no right or wrong.

To revert to the title fund of this thread, below is the fund's performance, taken from its quarterly reports, which are available its website
https://www.palmvalleycapital.com/fundcommentary
and are separate from Cinnamond's occasional other comments
https://www.palmvalleycapital.com/commentary.
The fund commentaries report overall return, its cash percentage, the performance of its equities and the performance of the two small cap benchmarks it uses. In the five years since inception it has underperformed its benchmarks by less than its expense ratio, while providing a smoother ride. One might consider 20% of the fund as part of one's small cap apportionment and 80% as part of one's (attached, so not liquid) cash apportionment.

PVCMX's  PVCMX's  PVCMX's  S&P SmCap   M* SmCap
Overall  Percent  Equity   600 Index   Tot Retn
Quarter   Return   Cash     Return   Return      Index
-------   -------  -------  -------  ---------   --------
2019 Q2    0.70%   91.8%    Absent     -1.93%      -1.35%
2019 Q3    0.50    92.9     > BMks     -0.20       -1.81
2019 Q4    0.22    92.4     Absent      8.20        8.67
2020 Q1    0.79    52.0     Absent    -32.65      -31.61
2020 Q2   10.74    72.5     27.3%      21.94       25.47
2020 Q3    0.89    70       ~=BMks      3.17        4.90
2020 Q4    5.78    Absent   22.14%     31.27       29.29
2021 Q1    3.60    80       19.10      18.23       11.62
2021 Q2    1.16    81.4      6.94       4.50        4.23
2021 Q3   -1.06    79.8     -3.40      -2.85       -3.67
2021 Q4    0.04    79        1.34       5.59        3.72
2022 Q1    1.94    80       10.85      -5.64       -6.18
2022 Q2   -0.74    75.8     -3.22     -14.13      -16.44
2022 Q3   -1.83    76.6     -8.66      -5.20       -3.75
2022 Q4    3.86    78.9     15.36       9.19        8.05
2023 Q1    3.01    79       12.2        2.57        4.90
2023 Q2    1.62    82        4.78       3.38        5.60
2023 Q3    0.56    81       -0.78      -4.93       -4.56
2023 Q4    4.00    77.7     14.25      15.12       14.07
2024 Q1    1.04    81.9      2.11       2.46        5.69
Since
Inception  7.55                         8.47        8.31
(04/30/19)

excellent. is maxdraw daily or month end?

Drawdown seems based on daily data. Here is the run for 2020 only to see more details of the credit freeze then,
https://tinyurl.com/yc5rumev

Some old articles I am yet to read. I am using this post as a place holder to come back and read later. In the meantime, feel free to read the articles and discuss.
https://www.bisnow.com/national/news/capital-markets/blackstones-new-york-office-tower-loss-a-siren-for-troubles-in-safest-cmbs-traunches-124405
https://www.bis.org/publ/qtrpdf/r_qt1412w.htm
https://www.actuary.org/sites/default/files/2022-12/C1_Presentation_CLOs.pdf
https://statmodeling.stat.columbia.edu/2018/10/16/aaa-tranche-subprime-science-revisited/
https://www.schwabassetmanagement.com/content/clos-are-not-cdos-why-they-arent-likely-to-topple-banking-system
https://www.spglobal.com/marketintelligence/en/news-insights/latest-news-headlines/leveraged-loan-news/those-700b-in-us-clos-who-holds-them-what-risk-they-pose
https://www.oaktreecapital.com/docs/default-source/default-document-library/clo-myth-busting.pdf?sfvrsn=42f25b66_16
https://www.janushenderson.com/en-us/advisor/article/how-a-hawkish-fed-may-impact-aaa-clo-returns/
https://www.pgim.com/press-release/pgim-launches-aaa-clo-etf-paaa-and-short-duration-multi-sector-etf-psdm

Capital and KKR are planning a series of hybrid funds that will invest in both publicly and privately traded assets. The first two strategies, expected to launch next year, will hold about 60% in public bonds picked by Capital managers, and 40% in direct and asset-based loans sourced by KKR.

These are likely the asset allocation or balanced funds. Really have to monitor these funds as they evolve.
TRP has a global allocation fund with 10% in private equity, and the fund is very average in performance for a number of years.

Description reads like a credit fund and not a hybrid allocation fund. May be the hybrid is public- private credit hybrid?

Capital and KKR are planning a series of hybrid funds that will invest in both publicly and privately traded assets. The first two strategies, expected to launch next year, will hold about 60% in public bonds picked by Capital managers, and 40% in direct and asset-based loans sourced by KKR.

These are likely the asset allocation or balanced funds. Really have to monitor these funds as they evolve.
TRP has a global allocation fund with 10% in private equity, and the fund is very average in performance for a number of years.

Yup. I didn't like the (then) 10-15% Blackstone Black Box they were promoting in RPGAX. I was interested in the fund to compliment PRWCX but I like knowing what I own!

The following proves that PVCMX is not an absolute return fund, see (https://www.investopedia.com/terms/a/absolutereturn.asp)
Quote "an absolute return fund seeks to make positive returns by employing investment management techniques that differ from traditional mutual funds. Absolute return investment strategies include using short selling, futures, options, derivatives, arbitrage, leverage, and unconventional assets. Absolute returns are examined separately from any other performance measure, so only gains or losses on the investment are considered."
The manager uses his unique strategy which depends mainly on owning cash equivalent positions when he can't find stocks that meet his criteria. I call it timing the markets.
JD, since retirement in 2018, I hardly owned stock funds. I'm mainly a bond OEFs trader. In extreme market risk, I'm at 99+% in MM.

Capital and KKR are planning a series of hybrid funds that will invest in both publicly and privately traded assets. The first two strategies, expected to launch next year, will hold about 60% in public bonds picked by Capital managers, and 40% in direct and asset-based loans sourced by KKR.

These are likely the asset allocation or balanced funds. Really have to monitor these funds as they evolve.
TRP has a global allocation fund with 10% in private equity, and the fund is very average in performance for a number of years.

Wouldn't expect this from conservatively-run juggernaught Capital, but here they are. I hope these funds don't tarnish their reputation by getting too ... creative. (I hold several large long-long-loooong term positions in various of their equity funds)
Per WSJ:
Capital Group, the stock-picking juggernaut whose American Funds have been a staple in brokerage accounts for nearly a century, is tapping private-equity pioneer KKR to step into the lucrative world of private investments.
Capital and KKR are planning a series of hybrid funds that will invest in both publicly and privately traded assets. The first two strategies, expected to launch next year, will hold about 60% in public bonds picked by Capital managers, and 40% in direct and asset-based loans sourced by KKR.
The new funds will target mass-affluent clients, or those who invest between $100,000 and $1 million. These customers hold the biggest chunk of the assets in wealth accounts, and represent the next frontier for firms that manage alternative assets such as private companies, loans and real estate.
Capital and KKR also intend to explore multiple flavors of hybrid funds—and private assets—in different markets around the world.
< - >

The plan marks one of Capital’s biggest forays into private assets since the 1970s when it helped start a venture-capital fund that would later emerge as Sequoia Capital. The money-management industry has changed dramatically since then, as trillions of dollars flowed into low-cost funds that track market indexes.
For KKR, the partnership will help extend its reach beyond the ultrawealthy individuals and families who currently invest in its products through wealth managers and financial advisers.
“Roughly 5% of U.S. households would meet that qualification,” Nuttall said. “There is this whole universe that we’re not getting close to touching.”
Facing relentless pressure to lower their own fees, traditional stock and bond managers have turned to investing in alternatives. These investments still command higher fees, and are harder for index and exchange-traded funds to duplicate. The pitch for customers is a chance at market-beating returns.
< - >
https://www.wsj.com/finance/investing/american-funds-parent-launching-partnership-with-kkr-to-move-into-private-assets-114430d0?mod=hp_lead_pos5

@BaluBalu, keep an eye on the news.
Goldman Sachs had huge missteps into retail - Marcus online and Apple Card, both big money losers for Goldman Sachs. The expanding retail pie for Goldman Sachs to make money never happened. The relationship between Apple and Goldman Sachs may soon end and the new partner may be JP Morgan Chase (others considered were Citi, Capital One, Synchrony).
So, the current deal from Apple Card may soon change. You may not want to jump into something that may be good for a few months only.

Palm Valley lists the following:
Inception 4/30/2019
INVESTMENT PERFORMANCE (%) as of March 31, 2024
___________________ Quarter YTD 1 Year 3 Year Inception
Palm Valley Capital Fund 1.04% 1.04% 7.38% 4.55% 7.55%
S&P SmallCap 600 Index 2.46% 2.46% 15.93% 2.29% 8.47%
Morningstar Small Cap Index 5.69% 5.69% 21.51% 2.68% 8.31%

https://www.sec.gov/Archives/edgar/data/1014913/000110465924063686/tm2414610d1_497.htm
497 1 tm2414610d1_497.htm 497
Filed pursuant to Rule 497(e)
Registration No. 333-07305
1940 Act File No. 811-07685
FRONTIER FUNDS, INC.
Supplement to Prospectus Dated October 31, 2023
Frontier HyperiUS Global Equity Fund
Institutional Class Shares (FHYPX)
Service Class Shares (FHGSX)
The Board of Directors (the “Board”) of Frontier Funds, Inc. (the “Company”), based upon the recommendation of Frontegra Asset Management, Inc. (“Frontegra”), has determined to liquidate the Frontier HyperiUS Global Equity Fund (the “Fund”). Frontegra is the Fund’s investment adviser and Hyperion Asset Management Limited doing business as H.A.M.L. is the Fund’s subadviser. After considering a variety of factors, the Board concluded that it would be advisable and in the best interest of the Fund and its shareholders that the Fund be closed and liquidated as a series of the Company, effective as of the close of business on the liquidation date, June 10, 2024.
The Board approved a Plan of Liquidation that determines the manner in which the Fund will be liquidated. Pursuant to the Plan of Liquidation and in anticipation of the Fund’s liquidation, the Fund will be closed to new purchases, additional investments and incoming exchanges, except for purchases made through an automatic investment program or the reinvestment of any distributions or a purchase exception that is approved by the officers of the Company, effective after market close on May 22, 2024. After the Fund is closed to new investments, shareholders will be permitted to exchange their shares of the Fund for shares of the other available Frontier Funds or to redeem their shares of the Fund, as provided in the Fund’s prospectus, until the liquidation date. No redemption fees will be imposed by the Fund in connection with redemptions or exchanges; however, please note that your financial intermediary may charge fees in connection with redemptions or exchanges.
Prior to the June 10, 2024, liquidation date, the Fund will no longer actively pursue its stated investment objective, and H.A.M.L. will begin to liquidate the Fund’s portfolio. The Fund’s portfolio managers will likely increase the Fund’s assets held in cash and cash equivalents in order to prepare for an orderly liquidation and to meet anticipated redemption requests. As a result, the Fund is expected to deviate from its stated investment objective, policies and strategies.
Pursuant to the Plan of Liquidation, any shareholder who has not exchanged or redeemed their shares of the Fund prior to the liquidation date of June 10, 2024, will have their shares redeemed and will receive one or more payments representing the shareholder’s proportionate interest in the net assets of the Fund as of the liquidation date, after the Fund has paid or provided for all taxes, expenses and any other liabilities, subject to any required withholdings. The automatic redemption of Fund shares on the liquidation date will generally be treated the same as any other redemption of Fund shares for tax purposes, so that shareholders (other than tax-exempt accounts) will recognize gain or loss for income tax purposes on the redemption of their Fund shares in the liquidation. In addition, the Fund and its shareholders will bear transaction costs and tax consequences associated with the disposition of the Fund’s portfolio holdings prior to the liquidation date. The Fund expects to have declared and paid a distribution or distributions, which, together with all previous such distributions, will have the effect of distributing to the Fund’s shareholders all of the Fund’s investment company taxable income and net capital gain (after reductions for any available capital loss carryforward), if any, realized in the taxable periods ending on or prior to the liquidation date. The distribution or distributions will include any additional amounts necessary to avoid federal income or excise tax. Shareholders should consult their tax adviser for further information about federal, state and local tax consequences relative to their specific situation.
This supplement should be retained with your Prospectus for future reference.
The date of this Supplement to the Prospectus is May 21, 2024.

If one were "back testing a portfolio to forward implement" a retirement Withdrawal Strategy using PV as @yogibullbear has outlined above, what funds would you choose?
We can't count on the same results going forward but the hope is past performance at least rhymes with future performance and we adjust as we go.
Criteria:
ER under 1%
3 Fund Portfolio
4% WD Yearly
Minimum 7% total return on a 3,5,10 and 15 yr basis
No COLA - I prefer the portfolio's yearly balance and 4% WD be the determinant of the dollar amount of the WD
Here are some funds for consideration and comment:
90% + Equity Portfolio (VFINX, FBGRX, PRMTX, FSMEX, PRNHX)
Other Choices:
- I often see these choices as being index funds that capture the market as well as sector funds that attempt to capture the outsized gains of a sector.
aggressive-allocation
70/30 or 80/20 Allocation Funds (PRWCX, TSAIX, looking for more choices )
Other Choices:
- Manager risk can be a larger dynamic with these investments. When these funds get it right they often captures more of the upside while reducing some of the downside risk.
moderately-aggressive-allocation
60/40 or 50/50 Balanced Funds (FBALX, VBINX, VWELX, FPURX, VGSTX, GAOZX, DODBX, RBAIX, RGPAX, VGWAX)
Other Balanced Funds:
- Not all balance fund are created the same. This article separate balance funds into three categories - US-centric, Global, and Diversified
balanced-funds
Other considerations:
Low Draw Down / Low Volatility Funds
- Funds that focus on Bonds, Utilities, Preferred stock might fit in this category.
12-battle-tested-low-volatility-funds
and with ETFs:
7-yield-solution-4-etf-portfolio
(JEPI, NUSI, HNDL, HIPS)
These funds should consistently produce a minimum 7% total return that I'll call The 7% Solution - where a retiree "spends down" (WD 4% yearly) while allowing the remaining 3% to grows the portfolio for future inflation adjusted 4% WDs.

the distinction between cost method and lot selection
Exactly. Further, each - cost basis and lot selection - is a distinct legal (accounting) fiction. In reality shares owned are nothing but fungible writings in an electronic ledger. For the tax purpose of computing gain, the IRS offers two different methods of ascribing cost - average and actual. If there is no gain to be calculated for taxes (as is the case for tax-sheltered accounts), then there is no cost basis.
That doesn't preclude investors from thinking about how much money they made in buying and selling shares, regardless of whether they are taxed on cap gains. To facilitate this, brokerages often provide their own tax-sheltered "cost basis" calculations for investors to track gains in their minds. Though not on their 1040s.
To illustrate this dichotomy between tax purposes and investor perceptions, consider income averaging. Say you make $100K in a single year, but the IRS lets you average that income over five years. From your perspective, you made $100K up front; you've got $100K in your pocket. From the IRS perspective, you made $20K that year, and you'll make $20K over each of the next four years. Which is real, $100K all at once or $20K each of five years? You may say the former, since you've got $100K now, but if you're talking taxes, the $20K/year is the "real" interpretation.
Likewise, funds and brokerages have their own rules for calculating holding periods. These rules need not be consistent with each other or with tax rules.
Typically, funds (a) waive short term redemption fees on shares purchased via div reinvestment (including cap gain divs), and (b) apply the redemption fee (e.g. 2%) only to those shares sold within the short-term period as opposed to all shares sold in the transaction.
In contrast to (b), brokerages typically charge a flat short term trading fee if any of the shares sold are subject to the brokerage's short term fee. Fidelity, at least, explicitly waives fees on reinvested divs:

[Fidelity's short-term trading fee] does not apply to ... shares purchased through dividend reinvestment.

https://www.fidelity.com/bin-public/060_www_fidelity_com/documents/Brokerage_Commissions_Fee_Schedule.pdf
Finally, to illustrate the difference that ordering rules make, consider the following transactions:
Jan 4 - purchase 100 shares
Nov 25 - purchase 100 shares
Dec 28 - div reinvest - purchase 10 shares
Jan 16 (next year) - sell 110 shares
On a strict FIFO basis, 10 shares (purchased Nov 25) will have been sold within 60 days of purchase. If for the purpose of calculating a short-term redemption fee, reinvested divs are deemed to have been sold first, then the 110 shares sold will be the 10 purchased on Jan 16 and the 100 purchased on Jan 4. No fee will be assessed (assuming no fee is charged for redeeming div reinvestment shares).

Too many employees and not enough work, given productivity gains from automation / computerization. They are bored out of their minds, what else do you expect. It is all our fault for expecting too little and giving them whatever they whine for. I am sure the rest of the government is no better.