“Round 2” of Marketing Rule Enforcement Actions — Focus on Hypothetical Performance

On April 12, 2024, the U.S. Securities and Exchange Commission imposed fines and other sanctions on five registered investment advisers (RIAs) for violations of the Investment Adviser Marketing Rule (Rule 206(4)-1), which has now been in effect for nearly a year and a half. All five firms agreed to settle the SEC’s charges, resulting in aggregate fines of $200,000....
By: Akin Gump Strauss Hauer & Feld LLP

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