Brian Rubin

Eversheds Sutherland (US) LLP

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FINRA’s 529 plan share class initiative

On January 28, 2019, the Financial Industry Regulatory Authority, Inc. (FINRA) launched its 529 Plan Share Class Initiative (the Initiative) to encourage member firms to self-report potential violations of rules governing 529...more

2/8/2019 / 529 Plans , Broker-Dealer , Exchange-Traded Products , Financial Industry Regulatory Authority (FINRA) , Internal Revenue Code (IRC) , Mutual Funds , Securities and Exchange Commission (SEC) , Self-Reporting , Share Classes

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

12/12/2018 / Disclosure Requirements , Enforcement , Investment Adviser , Mutual Funds , Registered Investment Advisors , Securities and Exchange Commission (SEC) , Self-Reporting , Share Classes

FINRA’s Variable Annuity Enforcement Efforts in 2018

From January through July 2018, the Financial Industry Regulatory Authority (FINRA) has continued its focus on variable annuities (VAs), particularly related to exchanges and multi-share class VAs. FINRA has thus far settled...more

8/3/2018 / Enforcement Actions , Financial Industry Regulatory Authority (FINRA) , Share Classes , Variable Annuities

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

2/22/2018 / Disclosure Requirements , Management Fees , OCIE , Registered Investment Advisors , Securities and Exchange Commission (SEC) , Share Classes

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