The SEC continues to push firms to make amends for compliance failures related to their revenue sharing agreements. The latest point of emphasis coming out of the SEC is from its Division of Investment Management (IM) – it issued a FAQ describing its expectations for firm communications with clients about fee arrangements with third parties and affiliates. Amy Lynch, FrontLine’s Founder and President, explains that in order for firms to create the proper disclosures informing their clients about revenue sharing specifics, compliance needs to have open channels of communication with business line personnel. Ms. Lynch further states that an effective process to access the appropriate data that determines the substance of disclosures, may be one of the greater challenges firms are facing. See IGNITES (subscription required), “Forget Me Not: SEC Reminds Firms of Rev-Share Disclosure Obligations”
