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Thought Leadership

SEC Enforcement Continues Thematic Focus on Hypothetical Performance

Read Time: 1 min

CONTRIBUTORS

Brad Bondi

Partner, Investigation & White Collar Defense

Anna Rips

Partner, Investment Funds & Private Capital

Ryan Swan

Partner, Investment Funds & Private Capital

Michael Wheatley

Of Counsel, Investigation & White Collar Defense

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.