SEC Staff Issues Important New Guidance on Presentation of Investment-Level Performance Under the Marketing Rule | JD Supra

SEC Staff Issues Important New Guidance on Presentation of Investment Level

On January 11, 2023, the staff of the Division of Investment Management at the US Securities and Exchange Commission (“SEC Staff”) updated their Marketing Rule FAQs. A new FAQ appears to impose the net performance presentation requirement at the investment-level (and not just the portfolio-level) under the amended Rule 206(4)-1 under the Investment Advisers Act … Read more