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Attorney Michael Caccese lays out a plan for getting ready for the SEC's new IA ad rule. Video runs 8:21
Although the new rule wouldn’t require pre-approval of ads, advisers may wish to adjust their internal marketing reviews to consider if any necessary “material” information ...
Compliance P&Ps tied to the ad rule “should include objective and testable means reasonably designed to prevent violations of the final rule in the advertisements ...
The Biden Administration has ordered its executives to hit the pause button on pending rulemaking efforts but the reprieve is too little, too late for ...
Various places in the rule note the CCO’s role in complying with it. Recordkeeping may well fall to compliance and, this is key
The new SEC advertising rule may someday be seen as a case of being careful what you wish for. Private fund advocates and others had ...
One CCO envisions creating an approval form that his advisers would submit. It would document who made the testimonial, whether the endorsement came in writing ...
The investment adviser must have a reasonable basis for believing that the testimonial or endorsement complies with the testimonial requirements
Virtually everyone RCW spoke with hailed the new rule, even if some parts rubbed them the wrong way.
This is how the new IA advertising rule defines an advertisement
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