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17 January 2017

Investment Management Division Provides Guidance On Mutual Fund Fee Disclosure Under Fiduciary Rule

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Herbert Smith Freehills Kramer LLP

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The SEC's Division of Investment Management published guidance stating mutual funds that modify fee structures and offer new share classes in order to comply with the Department of Labor's...
United States Finance and Banking

The SEC's Division of Investment Management published guidance stating mutual funds that modify fee structures and offer new share classes in order to comply with the Department of Labor's investment advice rule must clearly highlight the changes, which can be outlined in a prospectus appendix. The guidance further clarified how funds should disclose changes to sales loads leveling compensation for brokers, stating it should "specifically identify each intermediary whose investors receive a sales load variation" in a "clear, concise and understandable manner," using tables, schedules and charts as necessary to aid understanding. The SEC said it would not object to the use of a standalone appendix. Currently set to become effective on April 10, 2017, the rule faces an uncertain future as President-elect Donald Trump promised to either halt or dismantle it before implementation.

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