Marketing Exams Show Private Fund Shortcomings
FrontLine Compliance
The SEC’s Division of Examinations (the “Division”) recently issued a Risk Alert (the “Alert”) on its findings from private fund adviser examinations that covered compliance with revised Rule 206(4)-1 (the “Marketing Rule”). The specific areas of focus within the Alert reviewed the use of testimonials, endorsements, and third-party ratings in marketing materials.
The Alert indicates that many private fund advisers are falling short of compliance due to lack of proper disclosure practices, among other requirements.…