SEC Review of RIA Mutual Fund Revenue Disclosures – It’s Not Just 12b-1 fees!

The SEC recently announced its second wave of 12b-1 SCSD Amnesty Settlements.  It included one firm that was not a participant in the self-reporting initiative. It has also signaled that they are continuing to see these problems on exams, with firms who did not self-report.

More troubling, but not surprising is the expected expansion of SEC action with respect to other revenue streams. The SEC sued one firm for failure to disclose revenue sharing and transaction fee compensation involved in its mutual fund platforms.

CFI has assisted dozens of Firms and Outside Counsel in connection with the SCSD and related enforcement matters and has remediation templates for these additional revenue streams that are under review by SEC staff.