SEC’s new 2020 Advertising rule
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New SEC Advertising Rule
The adviser was also unable to substantiate performance claims, failed to disclose material conflicts of interest related to advertised testimonials and failed to implement certain ...
Delphia failed to lay out a clear advertising review and approval process, either in its policies and procedures or otherwise, that would enable its personnel ...
It’s been more than one year but SEC staff have released new FAQs tied to the IA advertising rule and they caution that net and ...
Senior personnel repeatedly violated policies by, among other things, sending emails to current investors, potential investors, and industry contacts which, in certain cases, unnecessarily disclosed ...
Our source describes the new document request letter from an ongoing exam as representative of a nationwide sweep by DOE examiners
A source shares with RCW a copy of a new DOE exam letter described as a new sweep exam tied to the new IA marketing ...
The adviser would 'periodically' have its disclosures 'reviewed and revised by WAM’s internal and external legal and compliance professionals, but those revisions did not adequately ...
Elm Partners published on its website at https://elmweath.com/returns-view that constituted advertisements because they offered Elm Partners’ investment advisory services with regard to securities to prospective ...
Hypothetical performance is defined as performance results that were not actually achieved by any portfolio of the investment adviser
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 ...