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Securities and Exchange Commission (SEC) Investment Adviser Testimonial Statements

Lowenstein Sandler LLP

SEC Settles Against Nine Investment Advisers for Marketing Rule Violations, Underscoring the Continued Priority of Marketing Rule...

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On September 9, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements with registered investment advisers for violations of Rule 206(4)-1, as amended (Marketing Rule), under the Investment...more

Goodwin

SEC Announces Focus Areas for Next Stage of Marketing Rule Exams

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On June 8, 2023, the Division of Examinations (EXAMS) of the Securities and Exchange Commission (the SEC) published a Risk Alert regarding its priorities for the next stage of examinations with respect to Rule 206(4)-1 (the...more

Stark & Stark

Use of Testimonials Under the New SEC Marketing Rule for Investment Advisors

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​​​​​​​The SEC’s new Marketing Rule compliance date was November 4, 2022. As part of the Marketing Rule, the SEC expanded advisers’ ability to use client testimonials in marketing materials. ...more

Holland & Hart LLP

New Investment Adviser Marketing Rule Now in Effect

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The transition period for recently adopted changes intended to modernize rules that govern investment adviser advertisements and compensation of solicitors has expired (effective November 4, 2022). The new rules revise and...more

ArentFox Schiff

SEC Adopts New Marketing Rule for Investment Advisors

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On December 22, 2020, the US Securities and Exchange Commission (SEC) adapted the rules that govern investment advisor advertisements and payments to solicitors. The amendments consolidated the previous advertising and cash...more

Troutman Pepper

The SEC’s New Marketing Rule - Practically Speaking: What Is an Advertisement?

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In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

Troutman Pepper

The SEC's New Marketing Rule - Practically Speaking: Testimonials and Endorsements

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In December 2020, the Securities and Exchange Commission (SEC) finalized amendments to its advertising and solicitation rules under the Investment Advisers Act of 1940, as amended. Those finalized amendments merged the...more

Seward & Kissel LLP

The New Investment Adviser Marketing Rule: Implications for CLO Managers and Arrangers

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On December 20, 2020, the SEC adopted reforms under the Advisers Act which modernized rules that govern investment adviser advertising and payments to solicitors. On September 19, 2022, the SEC Division of Examinations...more

Goodwin

Practical Guide to the Application of the Marketing Rule to Private Fund Placement Agents

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This article focuses on how the new Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) affects the relationships between investment advisers registered with the U.S. Securities...more

Hanzo

The Updated SEC Marketing Rule and How It’s Changed Archiving Requirements

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Toward the end of December 2020, the U.S. Securities and Exchange Commission (SEC) announced the release of a new comprehensive marketing rule. The original advertising rule had not been substantively amended or updated since...more

Miller Canfield

New Investment Adviser Marketing Rules Take Effect May 4, 2021

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On December 22, 2020, the SEC adopted amended Rule 206(4)-1 under the Investment Advisers Act of 1940, updating the rules governing investment adviser marketing ("Marketing Rules"). The new Rule replaces the currently...more

Kramer Levin Naftalis & Frankel LLP

SEC Adopts New Marketing Rule

The Securities and Exchange Commission (SEC) announced on Dec. 22, 2020, that it has finalized amendments to the current advertising rule (Rule 206(4)-1) and cash solicitation rule (Rule 206(4)-3) under the Investment...more

Bressler, Amery & Ross, P.C.

The SEC Adopts a Modernized Marketing Rule and the Testimonial Prohibition is No Longer

On December 22, 2020, the Securities and Exchange Commission (SEC) released an amended, “modernized” Rule 206(4)-1 of the Investment Adviser’s Act of 1940 (the “Marketing Rule”) citing advancements in technology, changes in...more

Dechert LLP

SEC Adopts Modernized Investment Adviser Marketing Rule Governing Advertisements and Solicitation

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On December 22, 2020, the U.S. Securities and Exchange Commission adopted rule and form amendments to modernize the regulatory framework governing investment adviser advertising and payments to solicitors....more

Faegre Drinker Biddle & Reath LLP

SEC Proposes Wide-Ranging Changes to Investment Adviser Marketing Rules

On November 4, 2019, the Securities and Exchange Commission (SEC) released a proposed rule amendment (the Marketing Amendment) that would substantially modify SEC Rules 206(4)-1 (the Advertising Rule) and 206(4)-3 (the...more

White & Case LLP

SEC Proposes to Modernize Advertising and Solicitation Rules for Investment Advisers

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On November 4, 2019, the Securities and Exchange Commission (“SEC”) issued a proposal to modernize the rules under the Investment Advisers Act of 1940 (“Advisers Act”) addressing SEC-registered investment adviser...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Dechert LLP

Financial Services Quarterly Report - Third Quarter 2015: Developing and Maintaining a Modern U.S. Compliance Program

Dechert LLP on

When the SEC adopted Rules 38a-1 under the Investment Company Act of 1940 (Investment Company Act) and 206(4)-7 under the Investment Advisers Act of 1940 (Advisers Act) in 2003 – which required registered funds and registered...more

Morrison & Foerster LLP - JOBS Act

The Guide to Social Media and the Securities Laws

The growing use of social media has created challenges for federal securities regulators, who must enforce antifraud rules that were written at a time when the prevailing technology was the newspaper. This Guide...more

Carlton Fields

SEC “Likes” Social Media for Investment Advisers

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The SEC staff views social media as a useful tool that helps consumers conduct their own due diligence on investment advisers. In a recent Investment Management Guidance Update, the staff stated that, under certain...more

Skadden, Arps, Slate, Meagher & Flom LLP

"SEC Issues New Guidance for Investment Advisers Regarding Use of Social Media Testimonials"

On March 31, 2014, the Division of Investment Management (the “Division”) of the Securities and Exchange Commission (the “SEC”) issued long-awaited guidance regarding investment advisers’ use of public commentaries on social...more

Dechert LLP

SEC Issues Guidance Update on Social Media Commentary in Investment Adviser Advertising

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The staff of the Division of Investment Management (Staff) of the Securities and Exchange Commission (SEC) has issued an IM Guidance Update (Guidance Update) on the use of social media in investment adviser advertising. The...more

Goodwin

SEC Staff Provides Guidance for Advisers Using Social Media on Compliance with General Prohibition on Testimonials

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The staff of the SEC’s Division of Investment Management (the “Staff”) issued IM Guidance Update No. 2014-4 discussing how a registered adviser or its investment advisory representatives (“IARs”) may use public commentary...more

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