Advisers

FYI: FAQs Issued on SCSD Initiative

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FYI: The SEC Division of Enforcement has issued FAQs addressing questions that have come up about the Share Class Selection Disclosure (SCSD) Initiative since it was announced earlier this year. (See my FYI blog post dated February 12, 2018, for more details on the Initiative.) In short, the Initiative encourages advisers to self-report to the SEC if the adviser failed to make required disclosures relating to its selection of mutual fund share classes that paid the adviser or its affiliates a 12b-1 fee when a lower-cost share class for the same fund was available. Among other things, the FAQs confirm […]