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SEC Issues Guidance for Funds on Fiduciary Rule-Related Prospectus Disclosures and Filing Procedures

The SEC recently released guidance for mutual funds in response to issues raised by the DOL Fiduciary Rule. The SEC observed that many funds are considering changes to fund fee structures, streamlined sales load structures and the addition of new share classes, among other things. The SEC noted industry concerns that such changes could lead to “lengthy prospectus disclosure that may be difficult for an investor to navigate and comprehend.” The guidance discusses how funds can make the appropriate disclosures, including adding an appendix to the fund’s statutory prospectus or by filing the appendix as a standalone document subject to certain conditions. The guidance also discusses filing procedures for new share classes and how funds may seek more efficient SEC staff review of such filings.