On January 11, 2023 the SEC Division of Investment Management issued an additional Marketing Rule FAQ. The newly issued FAQ addresses gross and net performance requirements applicable to private fund case studies, single investments and/or groups of investments, i.e. extracted performance. Specifically,
Division of Examinations Risk Alert: Observations From Broker-Dealer and Investment Adviser Compliance Examinations Related to Prevention of Identity Theft Under Regulation S-ID
The SEC Division of Examinations issued a Risk Alert on December 5, 2022 detailing observations from examinations of investment advisers and broker-dealers related to compliance with Regulation S-ID. Summary of Regulation S-ID Investment advisers that maintain “covered accounts” are required under Regulation
SEC Risk Alert Addresses Upcoming Examinations Relating to the “Marketing Rule”
The SEC Division of Examinations issued a Risk Alert on September 19, 2022 announcing examination initiatives relating to Advisers Act Rule 206(4)-1 – the “Marketing Rule.” The compliance date for the Marketing Rule is November 4, 2022. Any advertisements distributed by investment
Division of Examinations Risk Alert: Investment Adviser MNPI Compliance Issues
On April 26, 2022 the Division of Examinations of the United States Securities & Exchange Commission published a Risk Alert detailing investment adviser deficiencies related to Section 204A of the Advisers Act and Rule 204A-1 under the Advisers Act. By way of
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