For several years, the SEC’s Division of Enforcement has been taking action against investment advisers that make inadequate disclosures about the conflicts of interest associated with their mutual fund share class selection practices. Commencing in 2018, the SEC’s Share Class Selection Disclosure Initiative (SCSD Initiative) offered advisers the opportunity to resolve SEC charges by paying disgorgement and interest to affected clients – but without paying a financial penalty. Recent SEC settlement orders issued against two registered investment advisers may be the last enforcement proceedings under the SCSD Initiative. Simultaneously, the SEC issued a settlement order against an adviser that self-reported after the SCSD Initiative deadline and thus received a minimal fine. This article analyzes the terms of those settlement orders. See “SEC Continues to Pursue Advisers That Provide Inadequate Disclosures About Mutual Fund Share Class Selection Practices and Other Conflicts of Interest” (Nov. 15, 2018).