Advertising/Marketing

Broker-dealer charged for failing to preserve and review over 1.25 million business-related electronic communications on four platforms

The adviser was also unable to substantiate performance claims, failed to disclose material conflicts of interest related to advertised testimonials and failed to implement certain ...

Delphia failed to lay out a clear advertising review and approval process, either in its policies and procedures or otherwise, that would enable its personnel ...

New guidance raises more questions than answers, will 'ruin someone's two months,' compliance consultant says

It’s been more than one year but SEC staff have released new FAQs tied to the IA advertising rule and they caution that net and ...

Senior personnel repeatedly violated policies by, among other things, sending emails to current investors, potential investors, and industry contacts which, in certain cases, unnecessarily disclosed ...

Our source describes the new document request letter from an ongoing exam as representative of a nationwide sweep by DOE examiners

A source shares with RCW a copy of a new DOE exam letter described as a new sweep exam tied to the new IA marketing ...

The adviser would 'periodically' have its disclosures 'reviewed and revised by WAM’s internal and external legal and compliance professionals, but those revisions did not adequately ...

While the firm's compliance policy required advertising materials to be accurate, it did not adopt procedures for compliance personnel to verify the accuracy or completeness ...