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Private Funds Investment Management Marketing

Ropes & Gray LLP

[Podcast] Navigating the SEC's New Marketing Rule FAQ Guidance

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On this Ropes & Gray podcast, Alyssa Horton and Colleen Meyer, both counsel in the private funds regulatory group, explore the recent SEC staff guidance on the Marketing Rule. They discuss the new FAQs issued on March 19,...more

Paul Hastings LLP

SEC Updates Marketing Rule and Form PF FAQs in Short Succession

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On March 19, the SEC issued updates to its FAQs regarding compliance with Rule 206(4)-1 of the Advisers Act (the Marketing Rule) addressing (i) when gross and net performance are required for certain “extracted” performance,...more

McGuireWoods LLP

SEC Updates Marketing Rule FAQs to Provide Additional Performance Presentation Flexibility

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On March 19, 2025, the staff of the Securities and Exchange Commission (SEC) updated the FAQ page pertaining to Rule 206(4)-1 (the Marketing Rule) under the Investment Advisers Act of 1940. The updated guidance permits...more

Foley & Lardner LLP

Updated SEC Marketing Rule FAQ: Clarification Regarding Presentation of Net Extracted Performance

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On March 19, 2025, the Securities and Exchange Commission (SEC) staff issued an update to its frequently asked questions (FAQ) guidance with respect to registered investment advisers’ compliance with Rule 206(4)-1 (Marketing...more

Hogan Lovells

SEC staff releases guidance relaxing certain aspects of marketing and fundraising

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The Division of Investment Management of the U.S. Securities and Exchange Commission (the SEC) released new guidance on March 19, 2025 that replaces and relaxes prior guidance for registered investment advisers (RIAs) with...more

DLA Piper

SEC Clarifies When Gross-Only Performance May Be Permissible

DLA Piper on

The US Securities and Exchange Commission staff (Staff) has issued revised guidance regarding the application of Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (Marketing Rule), providing flexibility for...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

Akerman LLP

SEC’s Latest Marketing Rule Guidance: Key Takeaways for Advisers

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On March 19, 2025, the Securities and Exchange Commission’s (SEC) Division of Investment Management updated its Marketing Compliance Frequently Asked Questions (FAQ) to address industry confusion that has arisen in the wake...more

Morrison & Foerster LLP

SEC Staff Issues New Marketing Rule FAQs

On March 19, 2025, the staff of the SEC’s Division of Investment Management issued two new FAQs related to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the “Rule”). The new guidance reduces the complexity of the...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

Morgan Lewis

SEC Staff Issues Updated Marketing Rule FAQs

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SEC Staff published new guidance providing private fund managers and other investment advisers with flexibility to use extracted performance and portfolio/investment characteristics in marketing materials, without cumbersome...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for June 2024

Private Fund Rules Cancelled, Survey Says Marketing Rule is a Lot of Work and the Intersection of Regulation BI and Investment Adviser’s Fiduciary Duty - Welcome to our June Regulatory Roundup, where we provide you with a...more

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