Proper disclosure of the costs of investing, including disclosure of all fees and their potential effects on the value of investments, is critical for all firms. However, despite a focus, for years now, on this issue by the SEC, FINRA, and other regulatory bodies, some firms still do not adequately disclose to retail investors how the fees and expenses associated with particular types of investments will affect their returns.
The SEC has made the disclosure of the costs of investing a primary focus for 2018, and it is likely that we will see this issue remain an SEC priority well into the future as it dovetails with another critical issue - providing services to aging investors.
This focus on adequate fee and expense disclosure is not so much a result of firms deliberately avoiding proper disclosure as firms having, "practices or business models that may create increased risks," which include (but not necessarily limited to) the following:
- "Certain advisory personnel that may receive financial incentives to recommend that investors invest, or remain invested, in particular share classes of mutual funds where the investors may pay higher sales loads or distribution fees and the conflict of interest may not be disclosed to investors";
- "Accounts where investment advisory representatives have departed from the firms and the accounts have not been assigned a new representative to properly oversee them";
- "Advisers that changed the manner in which fees are charged from a commission on executed trades to a percentage of client assets under management";
- "Private fund advisers that manage funds with a high concentration of investors investing for the benefit of retail clients, including non-profit organizations and pension plans." [Source]