Category: Conflicts of Interest
Best Execution | Conflicts of Interest | Mutual Funds
Why the SEC is Obsessed with Mutual Fund Share Class Selection and Disclosure (and why you should be too)
On April 6, 2018, the SEC released three settlement orders with investment advisers because they “failed to disclose conflicts of interest and violated their duty to seek best execution by…
Best Execution | Conflicts of Interest | Disclosures | Mutual Funds | SEC News
SEC Offers “Favorable Terms” to Advisers that Self-Report Failure to Disclose Receipt of 12b-1 Fees
On February 12, 2018, the SEC Division of Enforcement announced a new self-reporting initiative – the Share Class Selection Disclosure (the “SCSD Initiative”). The Initiative, led by the Commission’s Asset…
Conflicts of Interest | Disclosures | Form ADV
SEC Imposes Strict Liability Standard on Advisers, Dismissing Due Care Defense
The first week of November was a time for surprises, but most surprising to me was the SEC’s decision in In re The Robare Group, Ltd. Back in 2015, I…
Conflicts of Interest | Department of Labor | DOL Fiduciary Rule | ERISA | Fiduciary
Q and A from Webinar on DOL’s New Fiduciary Rule
Questions & Answers from Webinar on: DOL Conflicts of Interest Rule Impact on Investment Advisers June 15, 2016 Does BICE apply when an adviser has a mutual fund and the…
Code of Conduct | Code of Ethics | Conflicts of Interest | Ethics
Trust but Verify: The SEC Addresses “Control” under Code of Ethics Rule
By: Jaqueline M. Hummel, IACCP®, AIFA® Managing Director Hardin Compliance Consulting LLC The SEC recently came out with guidance under Rule 204A-1 of the Advisers Act, which requires registered investment…
Compliance Program Rule, Rule 206(4)-7 | Compliance Programs | Conflicts of Interest | Examinations and Audits | Investment Advisers Act
Just in time for Halloween: Compliance Rule Horror Stories (Part 3 of a 3-part series)
October 30, 2014 Jaqueline M. Hummel Managing Director, Hardin Compliance Consulting, LLC In this final installment of a three-part series, the most recent cases involving violations of the Compliance Program…