Bates Group’s FINRA 529 Share Class Initiative Support for Firms

Last week, Bates sent a time-sensitive Alert concerning FINRA’s new Share Class Initiative. The initiative is similar to the SEC’s Share Class Initiative that focused on mutual funds in advisory accounts, except that FINRA’s focus is on 529 savings plans.

Bates has deep and proven experience and expertise in share class disclosure matters. Most recently, on behalf of over a dozen major national and regional financial institutions, Bates provided important assistance to firms and counsel participating in the SEC’s Share Class Selection Disclosure Initiative and related SEC Examinations. As a result of these efforts, companies have saved thousands of dollars in remediation costs and avoided reputational harm.

The deadline to self-report and provide FINRA with a remediation plan is April 1, 2019. FINRA cautions that “if a firm does not self-report under the 529 Initiative but FINRA later identifies supervisory failures by that firm, any resulting disciplinary action likely will result in the recommendation of sanctions beyond those described under the initiative.”