Glossary
SEC Marketing Rule
Definition
The SEC Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act, compliance date November 4, 2022) governs advertisements by SEC-registered investment advisers, including testimonials, endorsements and hypothetical performance such as projections.
How SEC Marketing Rule works
The adopting release treats interactive tools that clients use to run their own scenarios differently from adviser-presented hypothetical performance, provided the adviser explains the methodology, key assumptions and limitations, and that results vary with each use.
State-registered advisers follow their state's rules.
Why it matters to a firm
RIAs embedding projection calculators should review them with their CCO; our compliance guide summarizes the considerations.
Questions about SEC Marketing Rule
Who must follow it?
SEC-registered investment advisers.
Are calculators hypothetical performance?
Adviser-presented projections can be; client-run tools are treated differently with proper disclosures.
Can I show reviews?
Testimonials are allowed with conditions and disclosures.
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Related terms: Hypothetical performance · Investment analysis tool · Circular 230
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