Victoria A. Anglin

Apr 24, 2024 | lexology.com | W. Hardy Callcott |Chuck Daly |Elizabeth Shea Fries |Victoria A. Anglin |Joanne Saint Louis

On April 18, 2024, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (EXAMS) issued a Risk Alert summarizing the staff’s preliminary observations from examinations involving the compliance by registered investment advisers with Rule 206(4)-1 of the Investment Advisers Act of 1940, as amended (the Marketing Rule).

Sep 13, 2023 | lexology.com | W. Hardy Callcott |Stephen Cohen |Ranah Esmaili |Elizabeth Shea Fries |Lara Shalov Mehraban |Barry W. Rashkover | +2 more

On September 11, 2023, the U.S. Securities and Exchange Commission (SEC) announced settled charges against nine registered investment advisers arising out of violations of the investment adviser marketing rule (the Marketing Rule).1 Under the Marketing Rule, which was amended in December 2020, registered investment advisers are prohibited from including any hypothetical performance in their advertisements unless they have adopted and implemented policies and procedures reasonably designed to...