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Alan Markfeld
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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.
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Danielle Martin
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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.
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Curt Rocca
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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.
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Nicholas Di Paolo
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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.
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Margery Neis
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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.
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Joseph Burwell
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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!
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Faruk Jaffer
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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.
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everistus etafo
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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
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Karen Althaus
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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!
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SEC: Prudential Failed to Disclose Conflicts of Interest to Fund Boards

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The SEC alleged that insufficient enforcement of certain policies and procedures between Prudential and subsidiaries AST Investment Services Inc. and PIM Investments LLC (PI) cost 94 series funds tens of millions of dollars in interest income. The funds were reorganized in 2006 so that Prudential could receive certain tax benefits, but those benefits came with negative consequences to the funds. When AST and PI temporarily recalled securities which the funds had out on loan, AST and PI did not disclose to the fund's Boards of Trustees the inherent conflict of interest between Prudential and the funds in connection with the recalls. Furthermore, the 2006 reorganization subjected the funds to less favorable tax treatment in certain foreign jurisdictions, yet Prudential did not reimburse the funds in a timely manner despite AST and PI’s assurances it would reimburse the funds.

10 Years of Nondisclosure

From 2005 to 2015, AST and PI directed the funds’ securities lending agent to recall securities on loan from the funds in advance of the securities’ dividend record dates. The SEC assertions state that the sole purpose of the subsidiaries’ recall directive was to increase the tax benefit to parent company, Prudential Financial, and to Prudential insurance affiliates. During this 10-year period, the SEC contends that Prudential received more than $229 million in tax benefits at the expense of the funds and fund shareholders while the funds did not receive an estimated $72 million in securities lending revenue and additional investment income they would have made on that revenue. The SEC noted that AST and PI self-reported the conduct to the SEC (after initially failing to disclose it during an examination), cooperated with the staff's investigation, and voluntarily reimbursed the funds over $155 million. Nevertheless, the SEC ordered AST and PI to disgorge an additional $27.6 million and pay a civil monetary penalty of $5 million. These penalties emphasize the importance of actively looking into how all fees are being collected and how money is being made, and assessing and disclosing any related conflicts of interest. The fact that AST and PI identified and self-reported this situation  suggests that the penalties may have been mitigated (or perhaps avoided altogether) had the structure been analyzed with a focus on conflict issues and policies and procedures regarding reimbursements been implemented appropriately.

Checks and Balances

Although CCOs cannot be expected to know all tax laws and the intricacies of potential tax repercussions, they must communicate on a regular basis with those who do. When was the last time your firm reviewed and tested its policies and procedures regarding conflicts of interest and proper disclosures? Jacko Law Group has the necessary experience to recommend best practices and next steps. Contact our attorneys here.

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Jacko Law Group provides tailored legal services and effective strategies for success, delivering exemplary solutions to complex legal and regulatory challenges to ensure that both business efforts and compliance obligations are satisfied.

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