For clarification I will use RYCEY, because that is the specific company I am interested in, but I assume what applies to RYCEY ADRs is the same across the board for all ADRs. I can't find any good and clear resources about RYCEY ADR fees and I'm not sure how exactly they are assigned. I know before when RR paid a dividend the fee was deducted from the dividend, but now without the dividend it is just an annual charge. I know earlier this year the fee was $0.02/share and the record date (which I believe is the date the fee was collected) was June 18th. As shown here at J.P. Morgan ADR records for RYCEY

My question is, is the ADR fee applied ONLY to those that are holders of the stock on the exact date the fee is charged or does anyone that owned the stock at any point during that year also get charged even if they don't still own the stock at the time the ADR fee is collected?

Here are 2 examples I am interested in:

Example 1: I own 10,000 shares long term (assuming $0.02 fee) I get charged $200/year on the "record date."

Example 2: I'm a day trader; I buy and sell 10,000 shares 5 times throughout the year, BUT make sure not to own the stock on the day the ADR fee is collected. (assuming $0.02 fee) Do I pay $0 in fees OR do I pay $1,000 in fees since I bought and sold 10000 shares 5 times throughout the year?