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“Round 2” of Marketing Rule Enforcement Actions — Focus on Hypothetical Performance

On April 12, 2024, the U.S. Securities and Exchange Commission imposed fines and other sanctions on five registered investment advisers (RIAs) for violations of the Investment Adviser Marketing Rule (Rule 206(4)-1), which has...more

SEC Staff Extends ‘Net’ Performance Presentation Requirement to Case Studies

As a general principle, the Marketing Rule requires registered investment advisers to include net performance alongside any presentation of gross performance. Market practice on whether or how this principle applies to case...more

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