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Unrepresentative Returns: SEC Sanctions Hedge Fund Manager for Misleading Marketing Practices

On June 14, 2024, the SEC announced an enforcement action settlement with a Pennsylvania-based hedge fund manager for violating the Marketing Rule under the Investment Advisers Act. The SEC found that the adviser had misled...more

FINRA Proposes to Amend Rule 2210 to Permit Projected Performance and Targeted Returns in Institutional Communications

On November 13, 2023, FINRA filed with the SEC a proposal to amendment to Rule 2210 that would create a tailored exception from the general prohibition on projections in marketing materials and other communications with...more

Complying with the New SEC Marketing Rule: Seven Months in and Still Adapting

On November 4, 2022, compliance with amended Rule 206(4)-1 (the “Marketing Rule”) became mandatory for all investment advisers registered with the Securities and Exchange Commission (the “SEC”). Seven months since the...more

SEC Breaks its Silence on the New Marketing Rule's Net Performance Requirements

The SEC staff has issued an FAQ related to amended Rule 206(4)-1 under the Investment Advisers Act (the “Marketing Rule”) clarifying that the net/gross rules apply to extracted performance that may consist of returns of...more

Q&A: The Bottom Line of Complying with the SEC’s New Marketing Rule

In the late fall of 2020, the SEC implemented rule amendments which created a single rule, the Marketing Rule, that replaces the current Advertising and Cash Solicitation Rules. The Marketing Rule represents both significant...more

SEC Issues Risk Alert Announcing Exams Focused on New Marketing Rule

On Monday, September 19, 2022, the SEC’s Division of Examinations issued a Risk Alert announcing their intent to conduct targeted reviews of registered investment advisers regarding compliance with amended Advisers Act Rule...more

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