News & Analysis as of

Share Classes Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations

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

Troutman Pepper

Investment Management Update - January 2020

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SEC Proposes to Update Accredited Investor Definition to Increase Access to Investments - On December 18, 2019, the Securities and Exchange Commission (SEC) proposed amendments to the definition of “accredited investor” in...more

Perkins Coie

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

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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

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

Carlton Fields

SEC Probes Share Class Recommendations

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In July, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) announced an initiative to identify instances where registered investment advisers may be improperly influenced by...more

Ballard Spahr LLP

Investment Management Update

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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

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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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