Advertising/Marketing

When advertising the performance of a private fund, the adviser presented performance returns that were experienced by a single investor. These returns did not constitute ...

'It is still very much an open question about whether the marketing rule has helped investors as much as it has made the lives of ...

Risk alert identifies shortcomings in advisers' P&Ps which "resulted in gaps for preventing violations of the marketing rule, books and records rule, or both"

The Division encourages advisers to reflect upon their own practices, policies, and procedures and to implement any appropriate modifications to their training, supervisory, oversight, and ...

The resounding message is don't advertise hypothetical performance on your public websites

Bradesco disseminated hypothetical performance in advertisements to a mass audience rather than presenting hypothetical performance relevant to the likely financial situation and investment objectives of ...

Credicorp failed to adopt and implement policies and procedures reasonably designed to ensure that the performance was relevant to the likely financial situation and investment ...

The advertisements included hypothetical performance that consisted of performance derived from model portfolios. The advertisements on the website were disseminated to the general public rather ...

InSight advertised hypothetical performance on its public website without adopting and implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant ...

On its public website and on various social media sites, GeaSphere included a promotional video called “The GeaSphere Difference” that made false and misleading statements