Account holders maintaining positions in American Depository Receipts (ADRs) should note that such securities are subject to periodic fees intended to compensate the agent bank providing custodial services on behalf of the ADR. These services typically, include inventorying the foreign stocks underlying the ADR and managing all registration, compliance and record-keeping services.
Historically, the agent banks were only able to collect the custody fees by subtracting them from the ADR dividend, however, as many ADRs do not regularly pay dividends, these banks have been unable to collect their fees. As a result, in 2009, the Depository Trust Company (DTC) received SEC approval to begin collecting these custody fees on behalf of the banks for ADRs which do not pay periodic dividends. DTC collects these fees from its participant brokers (such as IB) who hold the ADRs for their clients. These fees are referred to as pass-through fees as they are designed to be then collected by the broker from its clients.
If you hold a position in a dividend paying ADR, these fees will be deducted from the dividend as they have in the past. If you hold a position in an ADR which does not pay a dividend, this pass-through fee will be reflected on the monthly statement of the record date in which it is assessed. The fee will be reflected in the Deposits & Withdrawals section of the statement with the description 'Adjustments - Other' along with the symbol of the particular ADR it is associated with.
While the amount of this fee will generally range from $0.01 - $0.03 per share, the amounts may differ by ADR and it is recommended that you refer to your ADR prospectus for specific information. An on-line search for the prospectus may be conducted through the SEC's EDGAR Company Search tool.