February 19, 2024

SEC Staff Updates Marketing Rule FAQs

Seward & Kissel LLP

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Seward & Kissel LLP

Who may be interested: Registered Investment Advisers

Quick Take: The staff of the Division of Investment Management of the SEC recently updated its Frequently Asked Questions (FAQ) relating to compliance with Rule 206(4)-1 under the Investment Advisers Act of 1940. The update to the FAQ addresses the methodologies for calculating gross and net performance shown in advertisements.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.