"This case is yet another illustration of the overbreadth of the pay-to-play rule and another reminder of the way the rule hampers legitimate political participation"
"The regulatory gap described, therefore, is more optical than substantive; closing it amounts to little more than grade-grubbing"
The resounding message is don't advertise hypothetical performance on your public websites
Bradesco disseminated hypothetical performance in advertisements to a mass audience rather than presenting hypothetical performance relevant to the likely financial situation and investment objectives of ...
Credicorp failed to adopt and implement policies and procedures reasonably designed to ensure that the performance was relevant to the likely financial situation and investment ...
The advertisements included hypothetical performance that consisted of performance derived from model portfolios. The advertisements on the website were disseminated to the general public rather ...
InSight advertised hypothetical performance on its public website without adopting and implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant ...
On its public website and on various social media sites, GeaSphere included a promotional video called “The GeaSphere Difference” that made false and misleading statements
What's hot on current SEC exams, suggestions for extracted performance, a possible solution to the challenge of off-channel communications, and much more
A source tells us of a new inquiry seen in a current exam. Examiners are probing the use of so-called 'shared work platforms,' like Google ...