CLIENT ALERT: SEC Proposes Modernization of the Advertising and Cash Solicitation Rules for Investment Advisers
November 20, 2019 – The Securities and Exchange Commission recently issued a release proposing updates to both the advertising and cash solicitation rules. The attached Client Alert summarizes the significant proposed changes. Among other things, the proposed modifications may allow investment advisers more flexibility to report performance data to certain investors, and will provide a framework for utilizing social media within existing rules that govern how investment advisers advertise and communicate with investors. The proposed updates to the cash solicitation rule also expand the definition of “compensation” and extend the reach of the rule to investors in pooled investment vehicles.