Bressler, Amery & Ross attorneys Kerry Zinn and Jacqueline Aleman discuss the SEC’s recent actions in light of the 2018 Share Class Disclosure (SCD) Initiative, which encourages self-reporting for 12b-1 conflict disclosures. with co-author Jacqueline Aleman In February 2018, the Division of Enforcement of the U.S. Securities and Exchange Commission (SEC) launched a self-reporting initiative for investment advisers who recommended, purchased or...
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