Share Class Disputes

Our regulatory and investigations team has guided more than 70 firms in navigating complex share class selection issues and related regulatory matters. We deliver clear analysis, quantify potential investor impacts, and help firms respond with confidence.

As a result of its extensive work in this space, Bates Group has developed a high degree of familiarity with clearing firm data necessary for such analyses from NFS, Pershing, Schwab, and others. We have also developed and maintains proprietary databases of historical mutual fund fee information, which is leveraged in analyzing both lower cost share class availability and in quantifying potential harm.

Share Class Selection & SEC Disclosure Initiative

Analyzed mutual fund trading activity to identify lower-cost share classes.
Quantified 12b-1 fee differentials for repayment calculations.
Delivered investor-level insights and documented findings for regulators.

Revenue Sharing & NTF/TF Share Class Issues

Conducted expense analyses on conflicts tied to revenue-sharing arrangements.
Evaluated investor harm from expense ratio differences and transaction-fee avoidance.
Delivered precise disgorgement and harm quantification reports.

Cash Sweeps & Other Conflicts

Reviewed cash sweep options to assess expense ratio and yield differentials.
Excluded trades/accounts where conflicts did not apply (e.g., rebates, client agreements, denied waivers).
Ensured fair, defensible analyses regulators accept.

529 Plan Share Class Initiative (FINRA)

Identified breakeven points for C-shares vs. A-shares using DOB data, quantified excess costs, and analyzed systematic investment programs.

Comprehensive Support