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Client Alerts

SEC Enforcement Continues Thematic Focus on Hypothetical Performance

April 17, 2024

By Brad Bondi,Anna Rips,Ryan Swan,Michael Wheatley

and Mark Raymond

The SEC charged five more registered investment advisers with violating the Investment Advisers Act’s Marketing Rule by advertising hypothetical performance on their websites without adopting appropriate policies and procedures, among other violations.

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Contributors

Image: Brad Bondi
Brad Bondi

Partner, Investigation & White Collar Defense


Image: Anna Rips
Anna Rips

Partner, Investment Funds & Private Capital


Image: Ryan Swan
Ryan Swan

Partner, Investment Funds & Private Capital


Image: Michael Wheatley
Michael Wheatley

Of Counsel, Investigation & White Collar Defense