The SEC’s modernized marketing rule: implementation and challenges of the revised requirements
Late last year the U.S. Securities and Exchange Commission adopted a new marketing rule to replace the current advertising rule and the current cash solicitation rule, along with the numerous related no-action letters. The new rule came into effect on May 4, 2021. The adopting release gave existing investment advisers the option to continue to use the current rules and no-action positions until the November 4, 2022 compliance date or choose to transition in full to the new rule at any time before that date (partial compliance not permitted).
Although the new rule is meant to simplify and modernise the requirements, there are differences in the new rule versus the existing requirements and investment advisers should fully work though the practical effects of these difference on their operations and compliance programs before undertaking the transition.
AIMA, in conjunction with ACA Group and Dechert LLP, has prepared an implementation guide exploring the practical aspects of compliance with the new requirements introduced by the marketing rule.
Join us for a discussion of the practical aspects of implementing the new rule and the challenges arising from the new requirements as well as AIMA’s Implementation Guide, sponsored by ACA Group and Dechert LLP.
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