Investment Adviser Marketing Rule
Investment adviser marketing practices in the Trade and Geopolitical Risk sector sit under active scrutiny from the U.S. Securities and Exchange Commission, which finalized its Marketing Rule under the Investment Advisers Act in 2022 and has since issued examination priorities calling out performance advertising and testimonial compliance as specific deficiency areas. Firms that advise on trade-exposed portfolios face a compounding challenge: geopolitical risk content, country-risk ratings, and sanctions-adjacent commentary increasingly appear in client-facing materials the SEC treats as advertisements under Rule 206(4)-1. Compliance teams are currently mapping those materials against the substantiation and disclosure requirements before examination cycles hit.
Watch
- SEC Rule 206(4)-1 substantiation requirement for geopolitical risk performance claims
- SEC 2024 examination priorities: testimonial and endorsement compliance in adviser marketing
- Third-party risk ratings used in client materials may trigger the new definition of 'advertisement'
- Sanctions-related disclosures in adviser communications drawing increased SEC staff attention
- Whether hypothetical performance content in trade-risk briefings meets the one-on-one exclusion test
Recent material activity in Trade & Geopolitical Risk
Active monitoring in place across Trade & Geopolitical Risk. Material developments related to investment adviser marketing rule will appear here as they are published.