Transcription of ADVERTISING BY INVESTMENT ADVISERS Michael S. …
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ADVERTISING BY INVESTMENT ADVISERS Michael S. …
M:\AIMR - GIPS 2006\BOS-# ADVERTISING BY INVESTMENT ADVISERS Michael S. Caccese and Christina H. Lim1 This article was originally published as INVESTMENT adviser Regulation, A Step-by-Step Guide to Compliance and the Law, Chapter 7, Practical Considerations for Performance ADVERTISING by ADVISERS , Second Edition, Nov. 2006 Introduction Rule 206(4)-1 Definition of Advertisement Testimonials [A] Partial Client Lists [B] Ratings [C] Article Reprints Past Specific Recommendations [A] Performance-Based Recommendations [1] Partial List of Recommendations [2] Article Reprints [B] Non-Performance Based Recommendations Charts and Formulas Free Reports or Services Anti-Fraud Catchall Provision Performance ADVERTISING General Requirements Model Performance Hypothetical Backtested Performance Gross-of-Fee and Net-of-Fee Performance [A] Net-of-Fee Performance [B]
- 3 - § 6.1 Introduction Deficiencies in presenting investment adviser performance continues to be one of the top five problem areas identified by the Securities and Exchange Commission (“SEC” or
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