The SEC SCSD Initiative – Lessons Learned To Date

SEC and Regulatory Enforcement Defense partners Mary Hansen and Jim Lundy, and associates Antoinette Snodgrass and Benjamin McCulloch authored “The SEC SCSD Initiative – Lessons Learned To Date” for Practical Compliance & Risk Management for the Securities Industry.

In February 2018, the SEC announced the launch of its Share Class Selection Disclosure (SCSD) Initiative, which incentivized investment advisers to self-report to the SEC certain mutual fund share class selection and disclosure violations. In this article, Jim, Mary, Antoinette and Ben outline some key components of the SCSD Initiative, including the much-needed clarity it provides on the current state of the required disclosures for registered investment advisers reviewing and recommending 12b-1 fee-paying mutual funds for their clients and the lessons learned so far. The article also provides background on the Initiative; updates on the implementation and enforcement of the Initiative; the required settlement terms pursuant to the Initiative; and the possible consequences for firms that did not self-report.

Read “The SEC SCSD Initiative – Lessons Learned To Date.”