In September 2017, the OCIE issued a Risk Alert notifying advisors of the most common deficiencies related to the Advertising Rule. Interestingly, all the deficiencies identified involved misleading performance advertising. The takeaways from the Risk Alert are detailed below. Misleading Performance Results. The Staff observed advisers that presented performance results without deducting advisory fees. The…

The SEC requires registered investment advisers to maintain a compliance program that implements a written code of ethics and policies and procedures to enforce them. Insider trading is a serious regulatory violation that can be avoided, provided clear and concise policy to control and contain the misuse of non-public material information. The COE is also…

The SEC’s Division of Investment Management recently released a Guidance Update which provides important guidance for investment advisors to mutual funds on managing the acceptance of gifts and entertainment from those doing or hoping to do business with the investment adviser. The guidance discusses the inherent conflicts of interest presented by the receipt of gifts…

Just Released: The SEC Issues Guidance on Social Media Testimonials The proper use of social media particularly as it relates to maintaining compliance with the SEC’s prohibition on the use of testimonials in advertising has caused a lot of questions…and a bit of anxiety for investment advisors. The SEC has just released guidance that clarifies…

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