Share Class Disclosure Date | Jacko Law Group, PC

With the issue of investment advisers putting their clients into higher-fee share classes when a low-cost option is available continuing to be a problem - and the subsequent Share Class Selection Disclosure Initiative developed to combat the problem on a voluntary basis - the SEC has released an FAQ to help firms answer questions they may have about self-reporting share class violations. You can read the full FAQ here. It's important to note that such self-disclosure will not necessarily protect a firm from enforcement or necessarily reduce or eliminate penalties. Rather, the initiative is designed to provide favorable terms when enforcement takes place. This includes allowing an adviser to neither admit nor deny the findings, and, for eligible advisers, the commission not imposing a penalty - though again, this last part is not guaranteed.

Standardized, Favorable Terms Benefit Firms Who Know They Are in Violation

The main question that each firm must ask itself is whether or not it is in violation. If it's clear that conflicts of interest with respect to 12b-1 fees were not properly disclosed, the firm likely needs to consider taking advantage of the initiative. That being said, many firms are wary (and rightfully so) of blindly taking advantage of the initiative, which is what inspired the SEC to create the FAQ. Many firms are not entirely sure what, specifically, makes them eligible or ineligible for this initiative and what to expect if they decide to take advantage. With the looming deadline of June 12, 2018, every firm that might be eligible needs to read the FAQs closely and make a decision - even firms that have had this issue brought up during an OCIE exam need to self-report.

Consult With Our Quick Response Team for Regulatory Examinations, Formal Investigations, and Enforcement

If your firm is likely to take advantage of this initiative, you need a team on your side who is familiar with regulators, who understands the process, and who can help you navigate the complexities that you're about to encounter. Even though you plan on self-reporting, your firm still faces significant risk. Working with our Quick Response team allows you to enter this stressful situation with someone in your corner working hard to reduce penalties and fees while simultaneously looking out for the survival and longevity of your firm. Contact us to learn more.

    
 
 
       Posted on Google  
   
   Alan Markfeld 
 
 
 
 Trustindex verifies that the original source of the review is Google. Dharmi is an excellent securities lawyer who understands the law as it pertains to these cases.  She is extremely proactive and represents her clients well.  I highly recommend Jacko and Dharmi.
  
 
      Posted on Google  
   
   Danielle Martin 
 
 
 
 Trustindex verifies that the original source of the review is Google. I’ve had the privilege of working closely with this firm in my role as Chief Compliance Officer and I can confidently say they are an exceptional compliance partner.

Their depth of experience is immediately evidentand they bring a level of practical knowledge. What I truly enjoy is their ability to translate complex regulatory requirements into plain English, often using real, everyday examples that make implementation far more manageable.

They are also incredibly responsive and reliable. In a field where timing matters, their prompt communication and thoughtful guidance have been invaluable.

If you’re looking for a compliance attorney who combines expertise, clarity, and professionalism, I highly recommend them.
  
 
      Posted on Google  
   
   Curt Rocca 
 
 
 
 Trustindex verifies that the original source of the review is Google. Michelle and the team at Jacko Law Group have helped guide through a variety of critical circumstances as we ventured through the uncharted and unfamiliar territory of becoming and successfully operating as an RIA. I have particularly appreciated Michelle's personal involvement and genuine caring about us and our organization. She has been responsive and her counsel has been consistently on-point and helpful. She artfully guided us through our initial filing process and first SEC exam process - which went very well. Very grateful to Michelle and her team.
  
 
      Posted on Google  
   
   Nicholas Di Paolo 
 
 
 
 Trustindex verifies that the original source of the review is Google. Michelle and her team were excellent to work with, front to back.  They helped me to understand the challenges ahead and were always proactive in their consultation through every step of my transition.  JLG truly know the wealth management industry very well and did a great job of understanding the challenges unique to my business.  Without them, I can confidently say I would not have felt as comfortable through the transition as I did.  Fortunately, that's not something that stops there - Michelle and her team have kept in touch to ensure that I'm on top of certain administrative issues, trends, and simply showing me that they care about my business and success.  I look forward to continuing to work with them for many years to come.
  
 
      Posted on Google  
   
   Margery Neis 
 
 
 
 Trustindex verifies that the original source of the review is Google. Dharmi Mehta was extremely helpful when my business partner and I transitioned to a new RIA firm.  She and her staff were all very professional.  Her guidance during our transition was invaluable.  I highly recommend Dharmi and Jacko Law Group.
  
 
      Posted on Google  
   
   Joseph Burwell 
 
 
 
 Trustindex verifies that the original source of the review is Google. Dharmi and Amandeep were a delight to work with. They assisted me with a claim and stuck with me the entire way through. Dharmi's advice was invaluable, and I was most impressed by her clear and professional communication. From beginning-to-end, both Dharmi and Amandeep kept me well informed. Their entire team are proud of their work and rightfully so. Thank you!
  
 
      Posted on Google  
   
   Faruk Jaffer 
 
 
 
 Trustindex verifies that the original source of the review is Google. My mentor once told me that a good attorney is worth their weight in gold — and that couldn't be more true of Michelle and Amanda. Their expertise, professionalism, and responsiveness were top notch every step of the way. It's rare to find legal partners who are not only sharp and thorough, but also genuinely invested in your success. I’m grateful for their guidance and highly recommend them to anyone seeking trusted legal counsel.
  
 
      Posted on Google  
   
   everistus etafo 
 
 
 
 Trustindex verifies that the original source of the review is Google. It is my great Privilege to share my Review of what Atty Dharmi Mehta of Jacko Law Group did for me and by extension for my family.
From the first time complimentary conversation we had having  spoken to several other Lawyers ,l knew she was the right person for the Job .Because of her background as a former RR ,she was professional,kind, Empathetic,listened and was focused on fighting for me.
From a potential of been terminated with cause ,l was able to walk away with a clean U5 with a validation that l did nothing wrong except what was in the best Interest of my clients.
I hope nobody ever has to go through what l have Experienced, but  if you do ,you want Dharmi Mehta beside you .Rest assured your service Deserve 10 stars but this forum only allows 5.
Me and my family are forever grateful and will make sure that any RR who needs an advocate will know about you .
Everistus Etafo
  
 
      Posted on Google  
   
   Karen Althaus 
 
 
 
 Trustindex verifies that the original source of the review is Google. I have worked with Jacko Law Group for 2 different business situations that necessitated an attorney.  In both cases, the team was very thorough & competent.  Their attention to our situation and the extra effort they put into our case(s) was very much appreciated.  I would highly recommend Jacko Law Group!

Alan Markfeld

Dharmi is an excellent securities lawyer who understands the law as it pertains to these cases. She is extremely proactive and represents her clients well. I highly recommend Jacko and Dharmi.

Danielle Martin

I’ve had the privilege of working closely with this firm in my role as Chief Compliance Officer and I can confidently say they are an exceptional compliance partner. Their depth of experience is immediately evidentand they bring a level of practical knowledge. What I truly enjoy is their ability to translate complex regulatory requirements into plain English, often using real, everyday examples that make implementation far more manageable. They are also incredibly responsive and reliable. In a field where timing matters, their prompt communication and thoughtful guidance have been invaluable. If you’re looking for a compliance attorney who combines expertise, clarity, and professionalism, I highly recommend them.

Curt Rocca

Michelle and the team at Jacko Law Group have helped guide through a variety of critical circumstances as we ventured through the uncharted and unfamiliar territory of becoming and successfully operating as an RIA. I have particularly appreciated Michelle's personal involvement and genuine caring about us and our organization. She has been responsive and her counsel has been consistently on-point and helpful. She artfully guided us through our initial filing process and first SEC exam process - which went very well. Very grateful to Michelle and her team.

Nicholas Di Paolo

Michelle and her team were excellent to work with, front to back. They helped me to understand the challenges ahead and were always proactive in their consultation through every step of my transition. JLG truly know the wealth management industry very well and did a great job of understanding the challenges unique to my business. Without them, I can confidently say I would not have felt as comfortable through the transition as I did. Fortunately, that's not something that stops there - Michelle and her team have kept in touch to ensure that I'm on top of certain administrative issues, trends, and simply showing me that they care about my business and success. I look forward to continuing to work with them for many years to come.

Margery Neis

Dharmi Mehta was extremely helpful when my business partner and I transitioned to a new RIA firm. She and her staff were all very professional. Her guidance during our transition was invaluable. I highly recommend Dharmi and Jacko Law Group.

Joseph Burwell

Dharmi and Amandeep were a delight to work with. They assisted me with a claim and stuck with me the entire way through. Dharmi's advice was invaluable, and I was most impressed by her clear and professional communication. From beginning-to-end, both Dharmi and Amandeep kept me well informed. Their entire team are proud of their work and rightfully so. Thank you!

Faruk Jaffer

My mentor once told me that a good attorney is worth their weight in gold — and that couldn't be more true of Michelle and Amanda. Their expertise, professionalism, and responsiveness were top notch every step of the way. It's rare to find legal partners who are not only sharp and thorough, but also genuinely invested in your success. I’m grateful for their guidance and highly recommend them to anyone seeking trusted legal counsel.

everistus etafo

It is my great Privilege to share my Review of what Atty Dharmi Mehta of Jacko Law Group did for me and by extension for my family. From the first time complimentary conversation we had having spoken to several other Lawyers ,l knew she was the right person for the Job .Because of her background as a former RR ,she was professional,kind, Empathetic,listened and was focused on fighting for me. From a potential of been terminated with cause ,l was able to walk away with a clean U5 with a validation that l did nothing wrong except what was in the best Interest of my clients. I hope nobody ever has to go through what l have Experienced, but if you do ,you want Dharmi Mehta beside you .Rest assured your service Deserve 10 stars but this forum only allows 5. Me and my family are forever grateful and will make sure that any RR who needs an advocate will know about you . Everistus Etafo

Karen Althaus

I have worked with Jacko Law Group for 2 different business situations that necessitated an attorney. In both cases, the team was very thorough & competent. Their attention to our situation and the extra effort they put into our case(s) was very much appreciated. I would highly recommend Jacko Law Group!

Mergers & Acquisitions+

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Looming Deadline for Share Class Selection Disclosure — FAQs and What Firms Need to Know

Standardized, Favorable Terms Benefit Firms Who Know They Are in Violation

Consult With Our Quick Response Team for Regulatory Examinations, Formal Investigations, and Enforcement

About the author

Jacko Law Group, PC

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Mergers & Acquisitions+

Regulatory Compliance Counsel+

Corporate & Securities Litigation+

Private Funds & Transactions+

General Corporate Counsel+

Mergers & Acquisitions+

Regulatory Compliance Counsel+

Corporate & Securities Litigation+

Private Funds & Transactions+

General Corporate Counsel+

Looming Deadline for Share Class Selection Disclosure — FAQs and What Firms Need to Know

Standardized, Favorable Terms Benefit Firms Who Know They Are in Violation

Consult With Our Quick Response Team for Regulatory Examinations, Formal Investigations, and Enforcement

About the author

Jacko Law Group, PC

Related Insights

OCIE Announces Upcoming Cybersecurity Sweep – What it Means for Your Firm

Wrap Fee Programs in 2018 – Is Your Firm Prepared for SEC Scrutiny?

5 Steps to Proactively Prepare for an SEC Examination

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