News & Analysis as of

Share Classes Disclosure Requirements Conflicts of Interest

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

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

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

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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