Stroock Special Bulletin
"OCIE Issues Risk Alert Highlighting the Most Frequent Advertising Rule Compliance Issues"
On September 14, 2017, the Securities and Exchange Commission’s (the “SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting compliance issues relating to Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (the “Advertising Rule”), which the OCIE staff most frequently identified during the course of over 1,000 examinations of SEC-registered investment advisers. The Risk Alert follows the completion of OCIE’s recent “Touting Initiative”, which focused on advisers’ use of accolades in marketing materials and identified common deficiencies in the advertising practices of advisers.
This Stroock Special Bulletin provides an overview of the alert.