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The New Marketing Rule: A Focus on Performance

3rd Party Hosted Event
Date: 23 March 2021
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The long-awaited modernization of the Security and Exchange Commissions’ (SEC) Rule 206(4)-1 (Marketing Rule) under the Investment Advisers Act of 1940 was added to the Federal Register on 5 March 2021. The majority of changes that a firm will need to make in order to comply with the new rule are performance related.

ACA and K&L Gates hosted a detailed explanation of the specific performance requirements, how they differ from prior no-action letters, and what steps a firm should take now in order to be ready by the deadline.

Discussion topics

In particular, the webcast addressed:

  • Terminology – Definitions of the terms used by the SEC
  • Key considerations – Which changes should you be focusing on now?
  • Related, extracted, hypothetical, and portable performance
  • Net of fees – What fees should be reduced to get net returns?
  • Overlap with the GIPS® standards

ACA Group

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