March 7, 2025
Contact: IAA VP of Communications & Marketing Janay Rickwalder
The SEC staff has increased its engagement with the IAA and our members in recent weeks to issue much-needed relief under the Marketing Rule for investment advisers. Today, the SEC staff announced during the IAA Compliance Conference that they are considering two new Marketing Rule FAQs in the near future to address the significant implementation challenges that the IAA has raised with the staff.
The staff reported that they are considering publishing relief to address challenges stemming from an FAQ issued on January 11, 2023, which provides that the performance of individual positions included in an adviser’s advertisements must be presented on a net basis. The guidance would also address issues related to the presentation of yield, attribution, and other portfolio and investment characteristics.
This welcome guidance would remove impediments to advisers sharing important information with investors and reduce the risk of investor confusion. The updated guidance would permit advisers to advertise the performance of individual investments as well as portfolio and investment characteristics on a gross basis if the net and gross performance of the entire portfolio is also included prominently in the advertisement.
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