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Past Guidance is No Assurance of Future Guidance: SEC Staff Reverses Course with New Marketing Rule FAQs on Extracted Performance...

AT A GLANCE - On March 19, the SEC released updated guidance for compliance with Rule 206(4)-1 under the Investment Advisers Act of 1940, with two major revisions: (i) an update to prior guidance regarding the use of...more

US SEC Includes “Greenwashing” in Its Examination Priorities for the First Time

In its 2022 Examination Priorities, issued on March 30, 2022, the Division of Examinations (“Division”) of the United States Securities and Exchange Commission (“SEC” or “Commission”) uses the term “greenwashing” for the...more

The Social Media Guide: Social Media Compliance for Issuers, Broker-Dealers, & Investment Advisers

The use of social media raises securities law and compliance challenges for issuers, broker-dealers, and investment advisers. This Compliance Guide summarizes briefly some key principles. ...more

SEC Examinations Division Issues Risk Alert on ESG Products and Services

On April 9, 2021, the Division of Examinations of the US Securities and Exchange Commission (“Division” or “staff”) issued a risk alert to highlight the staff’s observations from its recent examinations of investment...more

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