Transitioning to the New Advertising Rule
The sweeping revision of the advertising and solicitor rules is perhaps the most dramatic change in IA regulation since the adoption of the Compliance Program Rule in 2003. While the SEC has provided an 18-month transition period due to its sweeping changes, many firms are taking advantage of this time to modify policies and procedures to ensure full compliance by November 4, 2022 (the compliance date). With an all or nothing compliance option, firms need to understand the nature and scope of this tectonic shift to effectively transition through the many changes the new rule brings. This session will review the revolutionary changes and identify and discuss possible approaches firms may take to address them in their policies and procedures. Special attention will be paid to the challenges of an all or nothing transition and how firms may approach their decision on when to comply.
After attending this session, attendees should be able to:
- Explain to your marketing staff how your current advertisements can change under the new rule
- Analyze the opportunities (and potential pitfalls) that can come with this risk-based rule
- Examine and revise your current policies and procedures
- Pamela Pendrell, Partner, CCO GlobeFlex Capital, L.P.
- Michael McGrath, Partner, K&L Gates
- Mederic Daigneault, Senior Director Consulting, NRS
For Whom: Designed to increase the professional competence of investment adviser professionals with legal, compliance and management responsibilities.responsibilities.
Suggested Skill Level: Advanced
Instructional Method: Group Internet-Based
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, especially Rule 204-2, to become familiar with the structure and terms, and sample SEC examination request lists.
Advance Preparation: None