Client Alert

SEC Enforcement Continues Thematic Focus on Hypothetical Performance

April 17, 2024

By John L. Budetti,Brad Bondi,Anna Rips,Ryan Swan,Michael Wheatley,& 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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Image: John L. Budetti
John L. Budetti

Partner, Corporate Department

Image: Brad Bondi
Brad Bondi

Partner, Litigation Department

Image: Anna Rips
Anna Rips

Partner, Corporate Department

Image: Ryan Swan
Ryan Swan

Partner, Corporate Department

Image: Michael Wheatley
Michael Wheatley

Of Counsel, Litigation Department

Image: Mark Raymond
Mark Raymond

Associate, Corporate Department

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