SEC staff issues new FAQs on the Marketing Rule, providing investment advisers with flexibility and clarity

On March 19, 2025, the Securities and Exchange Commission’s (SEC) Division of Investment Management staff (Staff) issued two new Frequently Asked Questions (FAQs) focused on Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (Marketing Rule). The FAQs focus on two specific areas: (1) the display of the gross performance of an extract in an advertisement without including corresponding net performance of the extract; and (2) the presentation in an advertisement of one or more...
By: Eversheds Sutherland (US) LLP

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