February 25, 2019

Jim Lundy Comments on Industry Reactions to SEC 12b-1 Share Class Disclosure Initiative

Chicago partner Jim Lundy was quoted in “As Settlements Near, Investor Advocates Back 12b-1 Initiative” in the February 25, 2019, edition of Compliance Reporter.

As firms near settlements with the Securities and Exchange Commission in its 12b-1 fee self-reporting initiative, investor advocates are expressing broad support for the year-long initiative, so long as it actually manages to drive changes in firm conduct. For the industry, however, Jim noted that the SEC’s self-reporting “SCSD Initiative” has been met with mixed industry reactions, and many have described this initiative as “regulation by enforcement” because the SEC used the Division of Enforcement and enforcement settlements, in lieu of the policy-making tools available through the SEC’s Division of Investment Management via proactive regulatory guidance.

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