Los Angeles partner Fred Reish wrote an article for Money Managers Compliance Guide titled, "Fiduciary Advice and 12b-1 Fees."

The article warns RIAs and broker-dealers to be particularly conscious of undisclosed payments and/or payments in addition to an advisory fee.  The DOL has gained a greater understanding of RIA and broker-dealer compensation and is actively investigating both.

Source: Money Managers Compliance Guide