News & Analysis as of

Disclosure Requirements Compliance Marketing

Kelley Drye & Warren LLP

NAD Decision Leaves Unanswered Questions about Content Creator Disclosures

P&G filed an NAD challenge against Dr. Squatch over posts that the company’s influencers and content creators made on TikTok. These creators participate in the TikTok Shop affiliate program through which they can earn a...more

Troutman Amin LLP

“Prepare for the onslaught of 64.1601 claims”: New Ruling Confirms Private Right of Action On Caller ID AND Extends Rule to SMS...

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Received an email from Andrew Perrong this morning entitled: “Prepare for the onslaught of 64.1601 claims.” He wasn’t kidding. This is a complete disaster. In Newell v. JR Capital, 2:25-cv-01419-GAM (E.D. Pa. July 16, 2025)...more

Kelley Drye & Warren LLP

NAD Releases Influencer Trust Index

This week, NAD released Influencer Trust Index: Consumer Insights 2025. The report starts by noting that last year, 82.7% of marketers in the US leveraged influencers in creative campaigns, driving the influencer marketing...more

Lowenstein Sandler LLP

FTC Click-to-Cancel Rule on Hold, but California’s Automatic Renewal Law Remains Intact: What Companies Need To Know

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On July 8, the Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission’s (FTC) "click-to-cancel" rule (FTC Rule), which would have required companies to provide customers with an easy, one-click method to...more

Stradling Yocca Carlson & Rauth

The Legal Side of Sweepstakes: What Every Brand Needs to Know

“It’s just a giveaway. What could go wrong?” You’d be surprised. A fun marketing initiative can quickly become a legal headache. Behind every good sweepstakes is a legal minefield—one that many brands don’t recognize...more

King & Spalding

New Marketing Rule FAQs Facilitate Compliance on Net Performance

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On March 19, 2025, the SEC Staff published two Marketing Rule FAQs that address some of the more challenging aspects of the Marketing Rule requirement to present net performance information. Specifically, the FAQs provide a...more

Lowenstein Sandler LLP

SEC Updates Guidance on the Use of Gross and Net Performance in Advertisements

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On March 19, the Securities and Exchange Commission (SEC) issued a new FAQ response1 that softens prior guidance on the use of gross and net performance in advertisements. The new FAQs (the New Guidance) reduce the burden of...more

Davis Wright Tremaine LLP

SEC Updates Marketing Rule Guidance

On March 19, 2025, the SEC made two significant updates to the Marketing Rule's FAQ page. DWT discussed the SEC's recently adopted Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940) in our 2024 post, and...more

McDermott Will & Schulte

SEC Eases Marketing Rule Net Performance Requirement

On March 19, 2025, the US Securities and Exchange Commission’s (SEC) Division of Investment Management updated its frequently asked questions (FAQs) related to Rule 206(4)-1 (the Marketing Rule) under the Investment Advisers...more

Hendershot Cowart P.C.

Major Changes to Texas Medical Board Rules: What Healthcare Providers Need to Know

Hendershot Cowart P.C. on

On January 9, 2025, the Texas Medical Board (TMB) implemented comprehensive changes to its rules, marking a significant shift in how medical spas, IV hydration clinics, and other healthcare facilities operate in Texas....more

Harris Beach Murtha PLLC

Tips for Proactively Avoiding Penalties for AI-Related Marketing Claims

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The Federal Trade Commission has taken an important step in the regulation of marketing claims relating to artificial intelligence with the launch of “Operation AI Comply.” This operation marks a significant shift in the...more

Hinch Newman LLP

What Digital Marketers and Influencers Need to Know About the FTC Final Rule Banning Fake Consumer Reviews and Testimonials

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As previously blogged about here, following notices of proposed rulemaking in 2022 and 2023, on August 22, 2024 the Federal Trade Commission finalized a rule that will impose monetary civil penalties false and misleading...more

DLA Piper

Horizon - ESG Regulatory News and Trends - September 2024

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Welcome to Horizon, DLA Piper’s regular bulletin reporting on late-breaking legislative and policy developments in ESG. Our aim is to scan the litigation, enforcement, and regulatory horizon to help inform business decisions....more

SEC Compliance Consultants, Inc. (SEC³)

Nine Advisers Face $1.24 Million Fallout from SEC’s Marketing Rule Sweep

September 30 is the SEC’s fiscal year-end, so it's no surprise to see an uptick in enforcement cases this month. The latest slew of settlements involved violations of the Marketing Rule (Advisers Act Rule 204(4)-1) for...more

Davis Wright Tremaine LLP

Investment Adviser Expectations in 2024

Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more

Oberheiden P.C.

Promoters, Endorsers, and Brokers: Understanding the Rules on Securities and Cryptocurrency Investment Advertising

Oberheiden P.C. on

Promoting securities, cryptocurrency, and other investment opportunities is fraught with legal risks. Individuals who engage in promotional activities must ensure that they have a clear understanding of the federal laws and...more

Akin Gump Strauss Hauer & Feld LLP

SEC Releases Risk Alert on EXAMS Process

Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - August 2023

Closed-End Fund Activism Update - Activist investors continue to take large positions in closed-end funds and engage in disruptive activity that may be harmful to long-term shareholders of retail closed-end funds. This...more

Lowenstein Sandler LLP

FTC Promulgates New Rules on Deceptive Endorsements, Fake Reviews, and False Testimonials

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Businesses that use and publish endorsements, reviews, or testimonials should be aware of the Federal Trade Commission’s (FTC) updated Endorsement Guides and proposed new rule banning fake reviews and testimonials. Here’s...more

Davis Wright Tremaine LLP

In a One, Two, Three Punch, the FTC Issues Updated Endorsement Guides

The lead-up to the July Fourth holiday was a busy time for endorsement and testimonial watchers—the FTC issued (i) its final, updated Guides to the Use of Endorsements and Testimonials in Advertising, (ii) an updated version...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Risk Alert Describes Examination Areas for Newly Registered Advisers

On March 27, 2023, the Securities and Exchange Commission’s (SEC’s) Division of Examinations issued a Risk Alert setting forth typical focus areas reviewed by the staff during its examinations of newly registered advisers....more

McDermott Will & Schulte

After Almost 25 Years, FTC Issues New Health Products Compliance Guidance

The Federal Trade Commission (FTC) announced its Health Products Compliance Guidance on December 20, 2022. The 2022 guidance updates and replaces the FTC’s 1998 guidance, Dietary Supplements: An Advertising Guide for...more

Seward & Kissel LLP

The New Investment Adviser Marketing Rule: Implications for CLO Managers and Arrangers

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On December 20, 2020, the SEC adopted reforms under the Advisers Act which modernized rules that govern investment adviser advertising and payments to solicitors. On September 19, 2022, the SEC Division of Examinations...more

Proskauer Rose LLP

Q&A: The Bottom Line of Complying with the SEC’s New Marketing Rule

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In the late fall of 2020, the SEC implemented rule amendments which created a single rule, the Marketing Rule, that replaces the current Advertising and Cash Solicitation Rules. The Marketing Rule represents both significant...more

Goodwin

Practical Guide to the Application of the Marketing Rule to Private Fund Placement Agents

Goodwin on

This article focuses on how the new Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”) affects the relationships between investment advisers registered with the U.S. Securities...more

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