In late 2020, the SEC adopted1 rule amendments that require SECregistered investment advisers to, by November 4, 2022, switch their compliance regimes from the SEC’s current Advertising and Cash Solicitation Rules (Rules 206(4)-1 and 206(4)-3, respectively) to that of the new Marketing Rule (numbered 206(4)-1). The Marketing Rule represents both significant continuity with and a significant departure from the current rules.
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