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Persistent Compliance Challenges with Mutual Fund Share Classes and Wrap Fee Programs

May 18, 2021
2:15 PM - 3:15 PM EDT
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Course Description:

In the mid- to late-2010s, the SEC focused its attention on both mutual fund share class selection and wrap fee programs. The Commission identified instances where fees paid by mutual fund investors were higher than others available. During the same period, the SEC identified instances in which full and fair disclosure for trading practices by wrap managers were not being provided to clients. This session will review the history of enforcement actions in these areas and identify how firms recommending mutual funds and wrap programs to clients can be sure they are meeting their fiduciary duties.

Learning Objectives

After attending this session, you should be able to:

  • Develop policies and procedures to prevent and detect problems in these areas
  • Assist your portfolio managers in understanding the criteria they need to consider when making a share class selection
  • Analyze the trading practices of wrap managers and sponsors used by your firm

This virtual course is being taught as part of the Spring 2021 Virtual Compliance Conference. To learn more, visit our main conference webpage.

William A. Haddad
Partner, Pasquarello Fink Haddad, LLC


Will Haddad is a commercial litigator and problem solver who represents companies and individuals in complex litigation and governmental investigations. Will also advises investment advisers and broker-dealer firms on compliance matters.

Will represents companies, executives, licensed professionals, and other individuals from different industries. He is particularly well acquainted with the investment advisory, broker-dealer, and private fund sectors of the financial services industry. His clients have also come from various sectors of the health care, biopharma, and social media industries.

Will handles civil litigation from initial pleadings through trial or hearing, where appropriate. He represents clients in commercial disputes, including matters relating to investments, professional services, closely-held businesses, non-compete and non-solicit matters, and in FINRA arbitrations.

Will assists clients with responses to SEC, FINRA, and Massachusetts Securities Division inquiries. He also has experience in whistleblower matters and advising investment advisers and broker-dealers on compliance issues (e.g., DOL fiduciary rule).

Prior to joining Pasquarello Fink LLC in 2016, Will was a partner at a Boston litigation boutique and, previously, practiced in New York at Shearman & Sterling LLP and in Boston at Collora LLP.

In 2001-2003, Will served as a law clerk to the Honorable Ernest C. Torres in the United States District Court in Rhode Island and, prior to that, as an extern in the prosecutor’s office of the war crimes court for the former Yugoslavia located in the Netherlands.


Amber L. Tatman
Senior Consultant, Investment Adviser and Broker-Dealer ServicesNRS


Amber joined NRS in 2014 as a Consultant in Investment Adviser and Broker-Dealer Services. Amber provides consulting services on a wide variety of regulatory issues regarding the Investment Advisers Act, FINRA Rules and other federal and state securities and insurance regulations and delivers comprehensive compliance solutions to investment advisers and broker-dealers.

Amber has over 20 years of wide-ranging experience in the financial services industry including compliance, supervision, trading, operations, training, management, and development. Immediately prior to joining NRS, Amber was Director of Network Office Supervision with Northwestern Mutual for twelve years.

Amber earned her Bachelor of Arts degree in Economics from Vanderbilt University, her Juris Doctor degree from the Indiana University’s Robert H. McKinney School of Law, and is a member of the Indiana state bar. She obtained her MBA after completing course work at Butler University and WGU-Indiana. She holds the Chartered Life Underwriter (CLU®) and Chartered Financial Consultant (ChFC®) designations from The American College, the Certified Financial Planner™ (CFP®) designation, and the Certified Regulatory and Compliance Professional (CRCP™) designation from the Wharton School’s FINRA Institute. She regularly speaks at conferences and webinars and writes on topics related to the financial industry.


Drew A. Ahrens
Senior ConsultantNRS


Drew Ahrens’ responsibilities as a Senior Consultant with National Regulatory Services include on-site compliance reviews, risk assessments, policies and procedures drafting and review, as well as other compliance related analyses for investment advisers, private equity funds, hedge funds and investment companies.

Drew joined NRS in 2010 and has worked in the compliance field for the past 30 years. Prior to his current role, Drew has had extensive experience as Chief Compliance Officer with Atlantic Trust, FIM Group and Henderson Global Investors, and as CCO of their respective mutual fund companies. Drew had also formed his own regulatory consulting firm, Crosswinds Consulting.

Drew has also worked for firms including PPM America as VP of Compliance, Cova Investment Advisory Corp. as Director of Investment Advisory Compliance and Van Kampen Asset Management in various compliance roles.

Drew’s unique background gives him a strong understanding of a firm’s regulatory and CCO responsibilities. He has exceptional experience with the Investment Advisers Act of 1940 and the Investment Company Act of 1940. He has worked with various financial products, some of which include fixed income, hedge funds, REITS, annuities, options, open-end and closed-end funds, digital assets and private equity investments. Drew has also had experience with building successful compliance programs from the ground up.

Drew holds a Bachelor of Arts degree from Western Illinois University and has completed a mediation skills certificate program from Northwestern University.


For Whom: Designed to increase the professional competence of Investment Advisers.

Suggested Skill Level: Intermediate

Maximum Recommended Credit Hours for this session will include CLE, IACCP® and CPE.

CA MCLE = 60 minutes
IACCP® = 60 minutes
CPE = 60 minutes

For more information, check out the NRS Continuing Education Guide.