New SEC Advertising Rule

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 ...

Macroclimate failed to save earlier versions of the relevant webpages

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 ...

This matter involves failures by MRA to comply with the Amended Marketing Rule