News & Analysis as of

Excessive Fees Conflicts of Interest

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Affiliated plan providers of big plans get slaughtered

Following a jury’s decision to award over $38 million to a class of more than 26,000 participants in Pentegra’s multiple employer plan, the issue of working with providers affiliated with the plan sponsor highlights the...more

Goodwin

Navigating the SEC's Focus on Private Fund Fees: Understanding the Trends and Mitigating Risk

Goodwin on

The following is an edited version of a conversation between Goodwin partners Jonathan Hecht and Isaac Vinyarsh. Before joining Goodwin, Jonathan spent more than a decade in the SEC’s Division of Enforcement, including...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

JP Morgan ponies up $9 million

A settlement has been in a lawsuit accusing fiduciaries of the JPMorgan Chase 401(k) Savings Plan of self-dealing. Records show that a settlement of $9 million will be made to “fully, finally and forever resolve, discharge...more

Proskauer - The Capital Commitment

SEC Enforcers Continue to Focus on Undisclosed Fees

In a series of enforcement cases over the past few months, the SEC has continued to bring actions focused on undisclosed fees charged to clients. Many of these cases have charged firms with fraud and other violations based on...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - September 2019

In this issue, we summarize regulatory, litigation and industry developments from May to September 2019 impacting the investment management sector, including SEC action on standards of conduct for broker-dealers and...more

Pillsbury Winthrop Shaw Pittman LLP

Private Funds Litigation/Regulatory Year in Review and 2019 Outlook

Although the SEC did not bring as many headline enforcement actions against private funds as in years past, it continues to devote substantial resources and attention on investment advisers. The SEC will maintain its...more

Dorsey & Whitney LLP

The SEC's National Exam Program 2019

Dorsey & Whitney LLP on

The SEC's Office of Compliance Inspections and Examinations (“OCIE” or the “Office”) announced its 2019 Examination Priorities just before Christmas and the current Government partial-shutdown (here). While nonemergency...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Google is facing a federal lawsuit in San Francisco over last week’s AP investigation that showed that the search giant “was sill tracking iPhone and Android device users, even if they turned off the ‘Location History’...more

Vedder Price

Investment Services Regulatory Update - July 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts - PROPOSED RULES - SEC Proposes New Rule to Permit Certain ETFs to Operate Without an Exemptive Order - On June 28, 2018, the SEC issued a proposed new rule under the...more

Vedder Price

Investment Services Regulatory Update - February 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Well here is where an advisory firm gets in trouble

A good chunk of my work as an ERISA attorney is working with financial advisory firms in managing their retirement plan practice especially with 401(k) plans. I have many registered investment advisory clients around the...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Oracle’s 401(k) and what doesn’t look right

A district court judge has ruled that Oracle will in have to defend itself regarding its 401(k) Plan. Plaintiffs allege the Oracle Corporation 401(k) Savings and Investment Plan “caused participants to pay recordkeeping...more

Katten Muchin Rosenman LLP

DOL Issues (Some) Additional Guidance on the Fiduciary Investment Advice Rule and Best Interest Contract Exemption

The US Department of Labor (DOL) has issued its first set of FAQs under the fiduciary investment advice rule (the “Rule”) and related prohibited transaction exemptions. In general, the Rule provides that parties providing...more

Ballard Spahr LLP

Investment Management Update

Ballard Spahr LLP on

Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

King & Spalding

SEC Enforcement Against Private Equity Firms - A Focus on Disclosure, Fees, and Conflicts of Interest

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The Securities and Exchange Commission announced two settled enforcement actions against private equity fund advisers last week involving certain fee practices and potential conflicts of interest. Consistent with its...more

Fox Rothschild LLP

It Is All About The Disclosures

Fox Rothschild LLP on

The SEC recently commenced an enforcement action against an investment advisory firm and its principal in connection with the failure to disclose material conflicts of interest in connection with new mutual funds that the...more

WilmerHale

Life and Annuity Series: Excessive Fee Cases

WilmerHale on

Below is an update on the "excessive fee" cases under section 36(b) of the Investment Company Act of 1940. Most of these complaints are now proceeding on the "sub-adviser" theory: that annuity contract-holders pay...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The White House wants a new fiduciary rule

The White House unveiled their plan to direct the Department of Labor to unveil a new fiduciary standard rule that will curb the conflict of interest and excessive fees that the White House says that mars 401(k) and IRA...more

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