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Share Classes Self-Reporting Broker-Dealer

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

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

Eversheds Sutherland (US) LLP

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

UB Greensfelder LLP

FINRA’s 529 Share Class Self-Disclosure Initiative: If It’s Good Enough For The SEC, It Must Be Good Enough For FINRA

UB Greensfelder LLP on

About a year ago, the SEC offered investment advisors the unique opportunity to report themselves to the SEC if they sold mutual funds to their clients that offered a lower priced share class than the class actually selected...more

Moore & Van Allen PLLC

The Clock is Ticking for Investment Advisers to Self-Report Mutual Fund Share Class Violations

Moore & Van Allen PLLC on

On February 12, 2018, the U.S. Securities and Exchange Commission announced an initiative to address undisclosed conflicts of interest by investment advisers in the context of mutual fund share classes. Dubbed the Share Class...more

Dorsey & Whitney LLP

SEC Targets Advisers With New Cooperation Initiative

Dorsey & Whitney LLP on

The SEC’s Division of Enforcement announced a new cooperation initiative addressed to investment advisers who have failed to disclose conflicts arising from the receipt of 12b-1 fees from mutual funds. In essence, the...more

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