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