$2M penalty against adviser over share class allocations

To meet this fiduciary obligation, HWIS was required to provide its advisory clients with full and fair disclosure that is sufficiently specific so that they could understand the conflicts of interest concerning HWIS’s advice about investing in different classes of mutual funds and could have an informed basis on which they could consent to or reject the conflicts. HWIS did not adequately disclose all material facts regarding the conflict of interest that arose when it invested advisory clients in share classes