News & Events

Partner David Blass was quoted in an article titled, “SEC Enforcement Sweep Targets Hypothetical Performance Under the Marketing Rule,” which was published by Private Equity Law Report. The article discussed the agency’s approach to enforcement of the amended Marketing Rule. David noted that the SEC was transparent about its intention to review compliance with the Marketing Rule at an early stage, and the recent series of enforcement actions appear to be a result of those examination efforts. He went on to further observe that there is a sense that the SEC is signaling a tougher stance against even “garden variety” compliance matters. In addition, David noted that merely being named in an SEC enforcement action has an impact that advisers are sensitive to and that it draws considerable internal resources and requires engaging with outside counsel.

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