People who didn’t sponsor a plan or weren’t involved in the retirement plan industry before 2012, think some 401(k) industry veterans like myself, are part of some multiverse when we talk about life before fee disclosure. The...more
Junk fees have made, and continue to make, state attorney general headlines with recent actions by Maryland and Rhode Island relating to consumer transportation. The rubber met the road when Maryland Attorney General Anthony...more
On February 7, a coalition of 19 state attorneys general (AG) filed a comment letter supporting the Federal Trade Commission’s (FTC) proposed Trade Regulation Rule on Unfair or Deceptive Fees (Rule). The state AGs echoed the...more
On August 9, District of Columbia Attorney General Brian L. Schwalb issued a Supplemental Business Advisory regarding restaurants’ obligation to properly disclose service fees and charges to diners. The advisory comes after...more
For my first year of law school, I had a renowned criminal law professor. He had a penchant for ties and an odd love for Melrose Place (I was a Dallas guy myself). For his final law exam, the fact pattern for the final exam...more
The Massachusetts Securities Division (MSD) recently announced that it is seeking comments on a proposed format to standardize the disclosure of investment advisory fees. This step should be noted by investment advisers...more
On September 19, 2014, the Supreme Court of Canada released a trilogy of decisions examining the standing of representative plaintiffs and the availability of consumer protection legislation in the class action context....more
The SEC settled administrative proceedings against Transamerica Financial Advisors, Inc. (the “Adviser”) over its failure to grant advisory fee breakpoint discounts to certain advisory clients based on the aggregation of...more
In 1994. H. Wayne Huzienga sold Blockbuster Video to Viacom for $8.4 billion. At its peak, there were 9,000 stores. Dish Network who bought Blockbuster a few years ago for $320 million, just announced the closing of the last...more
Guidance provides temporary relief from the August deadline for annual disclosures by participant-directed plans. On July 22, the U.S. Department of Labor (DOL) issued Field Assistance Bulletin 2013-02 (the Bulletin),...more
Topics we will cover: • Introduction • Issues with Control Groups • Issues with Prohibited Transactions • Fee Disclosure - Excerpt from Who is in the Control Group? • Aggregation Rules (Section...more