News & Analysis as of

Clean Shares

Carlton Fields

Expect Focus - Volume I, March 2017

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Regulators Demand Third-Party Risk Management - While third-party risk management has been a required component of an effective enterprise risk management program for many years, the topic is receiving elevated attention...more

Carlton Fields

SEC Staff Allows Brokers to Set Commissions for Mutual Fund “Clean Shares”

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On January 11, the SEC staff issued an interpretive letter to the Capital Group (CG Letter) stating that Section 22(d) of the Investment Company Act does not prevent brokers from charging commissions for effecting...more

Carlton Fields

SEC Facilitates Product Charge Variations

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SEC staff in December issued a Guidance Update that provides significant flexibility regarding how mutual funds and variable annuities (VAs) reflect multiple charge structures in their SEC registration statements....more

Kilpatrick

SEC Issues Guidance to Ease Fund Implementation of “Clean Shares”

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In January, we authored a post discussing an SEC no-action letter, dated January 11, 2017, to Capital Group (the “Capital Group Letter”), the parent company of American Funds. In the Capital Group Letter, the SEC agreed that...more

Dechert LLP

SEC Staff Clarifies Application of 1940 Act Section 22(d) to Brokers Selling Clean Shares of Mutual Funds

Dechert LLP on

In response to a request for interpretative guidance, the U.S. Securities and Exchange Commission staff (staff) advised on January 11, 2017 that Section 22(d) of the Investment Company Act of 1940 does not prevent a broker...more

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