Share Class Selection – Time is Short to Review Fees and Disclosures

On April 12, the SEC announced its Share Class Selection Disclosure Initiative (SCSD Initiative). Under the SCSD Initiative, “the Enforcement Division will recommend standardized, favorable settlement terms to investment advisers that self-report that they failed to disclose conflicts of interest associated with the receipt of 12b-1 fees by the adviser, its affiliates, or its supervised… READ MORE

Performance-Based Fees – Net Worth Test Threshold Increases to $2.1m

  The SEC has increased the net worth test threshold applied to “qualified clients” to $2.1 million.  Qualified clients that enter into advisory contracts in reliance on the net worth test prior to the effective date will be “grandfathered” in, under the prior net worth threshold.  The new requirement is effective August 15, 2016. The… READ MORE