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Policies and Procedures. Successful business, law and profit background
Hypothetical performance is defined as performance results that were not actually achieved by any portfolio of the investment adviser
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Linden Thomas disseminated hypothetical performance in advertisements to a mass audience rather than presenting hypothetical performance relevant to the likely financial situation and investment objectives ...
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Macroclimate failed to save earlier versions of the relevant webpages
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While advertising hypothetical performance, the adviser failed to adopt and implement P&Ps reasonably designed to ensure that the performance was relevant to the likely financial ...
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This matter involves failures by MRA to comply with the Amended Marketing Rule
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Because the hypothetical performance ad would be available to mass audiences, an adviser generally could not form any expectations about their financial situation or investment ...
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We believe that advisers generally would not be able to include hypothetical performance in advertisements directed to a mass audience or intended for general circulation
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Banorte advertised hypothetical performance on its public website without adopting and implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant ...
A peer shares a revised marketing P&P for the new SEC ad rule
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RCW has obtained evidence of the division’s latest sweep and it targets advisers that engage in hypothetical performance marketing
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