News & Analysis as of

Disclosure Requirements Securities and Exchange Commission (SEC) Share Classes

Faegre Drinker Biddle & Reath LLP

Two Stones, One Bird: SEC’s Double Whammy Against Advisory Firm

In a pair of settlements announced on July 28, 2020, the SEC charged VALIC Financial Advisors (the “Firm”) with two separate sets of violations that allowed the Firm to obtain millions of dollars in fees without providing...more

Carlton Fields

SEC Pressures Advisers on Undisclosed Conflicts

Carlton Fields on

We are actively looking for circumstances where an adviser is financially conflicted by incentives that could affect investment recommendations to clients. ... And I will tell you: the more we look, the more undisclosed or...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #23

Regulation Best Interest: SEC 2020 Examination Priorities—Examinations for Compliance With Reg BI and the Investment Adviser Interpretation - The SEC has issued its final Regulation Best Interest (Reg BI), Form CRS Rule,...more

Perkins Coie

SEC Scrutiny of Advisers’ Share Class Selection, Revenue Sharing and Disclosure Practices Continues Apace

Perkins Coie on

Over the past several years, U.S. Securities and Exchange Commission (SEC) enforcement activity has eroded the stability of the once-standard lineup of share classes available to mutual fund investors. Starting with...more

Faegre Drinker Biddle & Reath LLP

The SEC Files Another Litigated Disclosure Case – With More Violations

On August 29, 2019, the SEC filed a complaint against a registered investment adviser alleging failures to disclose four categories of conflicts of interest and seeking disgorgement of $10 million in undisclosed compensation....more

Kramer Levin Naftalis & Frankel LLP

SEC Sues Investment Adviser for Nondisclosure of Revenue Sharing Agreement Details

On Aug. 1, the Securities and Exchange Commission (the SEC) charged Commonwealth Equity Services LLC, dba Commonwealth Financial Network (Commonwealth), a registered independent investment adviser to private clients (but not...more

Dechert LLP

SEC Announces Results of Share Class Selection Disclosure Initiative

Dechert LLP on

The Securities and Exchange Commission announced on March 11, 2019 that it had settled charges against 79 investment advisers in connection with its Share Class Selection Disclosure Initiative (SCSD Initiative). This...more

Eversheds Sutherland (US) LLP

The other shoe has dropped – The SEC follows up with firms that didn’t self-report under the share class initiative

The Share Class Initiative - On February 12, 2018, the Division of Enforcement of the US Securities and Exchange Commission (SEC) announced the Share Class Selection Disclosure Initiative (Initiative), which informed SEC...more

WilmerHale

SEC Share Class Selection Disclosure Initiative: Practical Considerations and Lessons Learned

WilmerHale on

The Securities and Exchange Commission (“SEC”) has made a concerted effort over the last several years to address investment advisers’ conflicts of interests and to establish standards for associated disclosure failures...more

Dechert LLP

SEC Announces Share Class Selection Disclosure Initiative

Dechert LLP on

The Division of Enforcement (Division) of the U.S. Securities and Exchange Commission (SEC) on February 12, 2018, announced a Share Class Selection Disclosure Initiative (SCSD Initiative). Led by the Division’s Asset...more

Eversheds Sutherland (US) LLP

SEC’s share class selection disclosure initiative: what’s next

On February 12, 2018, the Division of Enforcement of the US Securities and Exchange Commission (SEC) announced the Share Class Selection Disclosure Initiative (Initiative) to encourage SEC registered investment advisers...more

Burr & Forman

SEC Announces Share-Class Enforcement Initiative for Advisers

Burr & Forman on

After several years of examination focus and a series of enforcement actions, the SEC’s Enforcement Division on February 12 announced a “Share Class Selection Disclosure Initiative” in an attempt to level-set industry...more

Dorsey & Whitney LLP

SEC Targets Advisers With New Cooperation Initiative

Dorsey & Whitney LLP on

The SEC’s Division of Enforcement announced a new cooperation initiative addressed to investment advisers who have failed to disclose conflicts arising from the receipt of 12b-1 fees from mutual funds. In essence, the...more

Eversheds Sutherland (US) LLP

SEC Staff Provides Guidance on Disclosure of Sales Load Variations and Filing of New Share Classes in Light of the DOL Fiduciary...

On December 16, 2016, the Division of Investment Management (IM) of the Securities and Exchange Commission (SEC) published a Guidance Update (the Guidance) providing guidance on disclosure issues and filing requirements...more

Ballard Spahr LLP

Investment Management Update

Ballard Spahr LLP on

The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...more

Morgan Lewis

SEC Examiners Focused on Fund Share Class Conflicts of Interest

Morgan Lewis on

OCIE recently published a Risk Alert announcing that it will examine the potential conflict of interest created by registered investment advisers being financially incentivized to recommend certain share classes to clients....more

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