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“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...more

Fee Calculation Settlement Presents Broader Liability Concerns for Private Fund Managers

A recent enforcement action against two affiliated wealth management businesses raises concerns over whether and how other registered investment advisers will be subject to sanctions for issues that arise in the ordinary...more

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