Whether or
not fee disclosure makes any difference depends on how the fees are disclosed.
Not exact matches
(Full
disclosure: I have offered to pay the $ 5 million «leak
fee» that producer Chris Nee said in a tweet was a reason those tapes have
not yet been released.)
The SEC's focus on the average net IRR
disclosures, which has
not been previously reported, marks a new phase in the agency's efforts to regulate private equity and comes at a time when the industry is already under pressure from investors to simplify its
fees and expenses structure.
Thus, reforms like stricter regulations on brokers,
disclosure of 401 (k)
fees, or requiring plan sponsors to offer more lower - cost index funds, would be band - aids; they wouldn't fix this fundamentally broken system.
The company would have to file a notice with the regulatory department; pay a registration
fee of $ 250; provide evidence of registration with FinCEN as a money services business; agree to
not invest or pledge virtual currency in its custody or control on behalf of others or to engage in the exchange or transfer of legal tender; and prove its policies for reporting,
disclosures, and compliance.
Written
fee disclosures, which are required by law, don't always have the effect they're meant to because «participants don't always read it.»
That's unfortunate given the erosive effect of 401 (k)
fees, but hardly surprising when you consider most 401 (k) providers charge hidden
fees that don't appear in participant statements or
fee disclosures.
And that's before anyone gets to scandals in Summers» past, like the comments on women in the sciences or the Shleifer affair,
not to mention the consulting and speaking
fees he'll need to report on his financial
disclosure forms.
I also think these advisors will have a tougher time competing with
fee - only advisors that won't need to have their clients sign a complicated BICE
disclosure document
See http://janebryantquinn.com/2010/09/have-an-annuity-with-lifetime-income-guarantees-dont-give-it-up/ I have written negatively about equity - indexed annuities (which the industry likes to call «fixed annuities,» even though they aren't fixed), due to lack of
disclosure, hidden
fees and, yes, abusive sales, as several lawsuits by attorneys general can attest.
While
not all providers with revenue sharing may be deemed fiduciaries, the risk of potential liability may cause many to evaluate their
fee disclosure procedures and make pre-emptive changes.
We probably would
not have the fuss over the fiduciary rule if total and prominent
disclosure of
fees were done.
Plan providers don't make this easy by providing
fee disclosures that are 15 to 45 pages long and use very opaque language in how this information is relayed.
Specifically, the new rule would: increase compensation for passengers involuntarily bumped from flights; allow passengers to make and cancel reservations within 24 hours without penalty; require full and prominently displayed
disclosure of baggage
fees as well as refunds and expense reimbursement when bags are
not delivered on time; require fair price advertising; prohibit price increases after a ticket is purchased; and mandate timely notice of flight status changes.
Amazon based its European headquarters in Luxembourg with the express intent of avoiding most of the tax
fees that plague international companies; however, in full
disclosure and with the intent of
not painting any «bad guys» in the scenario, a large number of companies follow the same real estate principle, including Google and Starbucks.
This
fee is a finance charge for federal law
disclosure purposes (even though
not included in any APR calculation).
These
fees are finance charges for federal law
disclosure purposes (even though
not included in any APR calculation).
The card also doesn't provide a straightforward
disclosure for the annual
fee.
Additionally,
fee - based investors tend to be less negatively impacted by mandated
disclosures, since commission - based accounts often include embedded
fees paid by the mutual fund companies that investors may
not know about.
And
not surprisingly, poor
disclosure and high
fees are positively correlated.
Since plan participants can
not change record keepers or even advisors on the plan, FeeX focuses on investment
fees — which might be easier to discover with the advent of 408 (b)(2) and 404 (a)(5)
disclosures.
And some funds might charge an upfront commission, which you might
not know about unless you review the
fee disclosure statement that all 401k plans are required to provide.
And there are also
disclosure risks if clients are
not explicitly made aware of such
fees (e.g., if they're buried deep in the paperwork).
Not easy to find all
fees: You'll need to scroll through a long account
disclosure to find two sets of
fees — account - specific ones and general
fees across accounts — which can be confusing.
In addition, the initial TRID 2.0 rule did
not address the «black hole» issue that prevented lenders from re-setting
fee tolerances when a closing
disclosure had been issued prematurely.
Commissions do
not need to be shown on your annual
fee disclosure statement, but some advice firms voluntarily include them.
CRM2 was a significant step toward
fee transparency, but because it doesn't require
disclosure of all costs associated with investments, investment advocates say that Canadian investors still have an incomplete awareness of the costs they pay.
A facilitator of a refund anticipation loan or refund anticipation check may
not advertise or market a refund anticipation loan without including in the advertising or marketing materials a
disclosure that the product is a loan and that tax refunds can be obtained without a loan or extra
fees if tax returns are electronically filed with direct deposit.
Most often, contracts for credit repair services do
not contain full
disclosures of a consumer's rights and responsibilities and fail to disclose all
fees and payments (including any fair share payments).
In addition, the plan's annual Form 5500 Department of Labor (DOL)
disclosures are supposed to identify the administrative
fees paid to TIAA, but they do
not clearly identify this information either.
We probably would
not have the fuss over the fiduciary rule if total and prominent
disclosure of
fees were done.
(b) the range of
fees for specifically described professional services provided there is reasonable
disclosure of all relevant and variable considerations affecting the
fees, so that the statement would
not be misunderstood or be deceptive including without limitation, an indication whether additional
fees may be incurred for related professional services which may be required in individual cases.
Disclosures would increase on subprime credit card
fees — Subprime cards carry upfront
fees that the Federal Reserve board contends are
not clearly disclosed to customers.
After reaping lots «more» hUge rewards like the 0.5 % you mentioned plus $ 25 for sign - up, Rogers Fido MCs provides
not much else in cutting out card benefits, i.e., Rogers / Fido MC disadvantages along charging FX
fees are missing consumer / travel protections like free roadside assistance, car rental CDW and purchase security insurances found on the Home Trust Preferred with «0 % Foreign Currency Conversion»
disclosure, i.e., unlike almost all credit card issuers like Rogers / Fido, Home Trust charging «no Foreign Transaction
fees» alone saves you all those initial
fee costs from the start.
One bit of important information that you will
not find on uTANGO's website is the «terms, conditions and
disclosures,» which contains important information such as interest rates,
fees and penalties, and the brass tacks on how to maintain your membership in good standing.
For example, in Colorado civil cases, some of the more common grounds for an award of attorneys»
fees to a defending party are: (a) a two - sided contractual
fee shifting term, (b) dismissal of the case before filing an answer for failure to state a claim when tort claims were asserted, (c) a determination that the suit was groundless, frivolous or vexatious, (d) violation of certain rules relating to
disclosure of information to the other party, (e) a statutory
fee shifting provision in the case of a claim based upon a statutorily created right which is present in some statutes but
not others.
For example, the defence could seek
disclosure of the redacted billing narratives and
fee notes being charged by the private prosecutor (these would
not be privileged).
So, for instance, the rules on
fee - sharing and referral
fees (now rr 8 and 9 respectively) have
not changed substantively since the decisions in late 2004; and the updated rules which cover conflict, and the clash between duties of confidentiality and
disclosure (rr 3 and 4) have been in place since April 2006.
In contrast, I have never had a family court order
disclosure of such records when the opposing party was
not seeking
fees.
Thus, Sally Azarmi, chair of the Small Firms Division of the Law Society said that
disclosure of
fees on the internet was «
not viable» and was incompatible with practice in other jurisdictions.
Accordingly, the Parties each agree and acknowledge that any such violation or threatened violation may cause irreparable injury to the Disclosing Party and that, in addition to any other remedies that may be available, in law, in equity, or otherwise, the Disclosing Party shall be entitled (a) to seek injunctive relief against the threatened breach of this Agreement or the continuation of any such breach by the Receiving Party, without the necessity of proving actual damages, and (b) to be indemnified by the Receiving Party from any loss or harm, including but
not limited to attorney's
fees, arising out of or in connection with any breach or enforcement of the Receiving Party's obligations under this Agreement or the unauthorized use or
disclosure of the Disclosing Party's Confidential Information.
The NPRM did
not address whether a covered entity could charge a
fee for the accounting of
disclosures.
Though
not specifically addressed by the rule, NAR recommends greater
disclosure of
fees paid to appraisers.
He then claimed to have asked the Real Estate Council of B.C. about
disclosure and indicated their response implied «that it's only the «EXTRA» income beyond our contracted
fee with our seller that we must declare —
not as you just put it in your article, and what we were first led to believe, that all
fees are to be declared to everyone.
The standard doesn't require that the
disclosure be included in a listing agreement or even that it be in writing, but it does require that the seller be told what the cooperative
fees will be.
Where a licensee receives remuneration, such as a referral
fee, as a result of making a recommendation to a client, or recommending a client to a party, the
disclosure must be in writing, but, it may
NOT be in a written service agreement or any other agreement giving effect to a trade in real estate.
9 DOS 94 Matter of DOS v. Shane - motion for pre-hearing discovery beyond SAPA 401 (6) is denied; rules re: subpoenas in administrative proceedings reiterated; proper procedure of reserving right to file post-hearing memorandum of law; MLS form listing agreements are acceptable; individual license
not sufficient to allow acting as representative of corporate licensee - need affiliated license; agreements procured by individual acting under name of firm but without affiliated license are illegal and unenforceable - no brokerage
fee can be claimed; misrepresentation and execution of unauthorized extension; misrepresentation of law (distinction between canceling agency authority and abiding contract rights); RPL § 443 controls the
disclosures required of licensees; subsequently licensed corporation
not vicariously liable; failure to provide copy of agreement (19 NYCRR 175.12); inadvertence considered in determining penalty
The Court of Appeals affirmed the jury award for fraudulent concealment, but reversed the punitive damage award and attorney
fees award, ruling that the Broker could
not be liable for violations of the Act because of the property
disclosure law.
While the lender is prepared to pay its standard compensation on each loan, what if a
disclosure error results in exceeding the tolerances on the Good Faith Estimate (GFE); a loan's
fees must be reduced to meet high cost (or Qualified Mortgage) thresholds; or appraisal or credit report charges are
not collected by the borrower?
However, if Eileen or her brokerage have been engaged by Dave to provide real estate services in the intervening period or they have an ongoing client relationship with Dave,
disclosure of this referral
fee, even though it was
not expected, is required at the time of its receipt.