Updated SEC Marketing Rule FAQ: Clarification Regarding Presentation of Net Extracted Performance
By EsqSocial Corporation 02/04/25
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 Rule) under the Investment Advisers Act of 1940 (Advisers Act). The FAQ provides new direction for advisers on the presentation of gross and net extracted performance data for a single investment or a group of investments (an “extract”) in marketing materials, as well as...
By: Foley & Lardner LLP