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Stradley Ronon Launches Revised Marketing Rule Task Force in Response to Upcoming SEC Compliance Deadline

September 26, 2022
Firm News

PHILADELPHIA – Stradley Ronon is pleased to announce the recent formation of the Revised Marketing Rule Task Force (the Task Force) in response to the U.S. Securities and Exchange Commission (SEC) adopting significant and complex amendments to Rule 206(4)-1 under the Investment Advisers Act of 1940 (the Revised Marketing Rule). The Revised Marketing Rule regulates the way registered investment advisers must advertise and market their products and services.

Partners and members of the firm’s nationally-ranked investment management group, Lawrence P. Stadulis and Peter M. Hong, will co-chair the Task Force. The group has significant regulatory and practical experience over many years of counseling investment advisory firms on advertising and marketing-related matters. The Task Force also has longstanding relationships with other experts in this area, including current and former SEC and trade association staff members.

“The fast-approaching compliance date for the Revised Marketing Rule is Nov. 4 of this year,” said Stadulis. “Therefore, the Task Force’s primary function is to assist registered investment adviser clients in bringing their advertising materials, marketing arrangements and related policies into compliance with the Revised Marketing Rule no later than the deadline.”

This assistance may vary in form and content depending on the needs of each client. At a minimum, however, the Task Force expects to make the following forms of assistance available:

  • Draft custom-tailored compliance policies and procedures.
  • Review and provide comments on specific advertising pieces.
  • Structure and properly document client referral and solicitation arrangements.
  • Respond to individual interpretive questions.
  • Provide compliance training to legal and compliance personnel, either remotely or in person.
  • Monitor ongoing developments and provide timely updates.
  • Where appropriate, reach out to the SEC staff for guidance on particularly thorny issues.

“While we have been advising our clients since the regulations were announced in December 2020, as a group, we felt that it was important to create a formal Task Force responsible for providing comprehensive resources and guiding our clients to the compliance finish line,” said Hong.

About Stradley Ronon
Counseling clients since 1926, Stradley Ronon has helped private and public companies – from small businesses to Fortune 500 corporations – achieve their goals by providing pragmatic, value-driven legal counsel. With offices in seven strategic locations, our responsive team of more than 200 attorneys seamlessly addresses the full spectrum of our clients’ needs, ranging from sophisticated corporate transactions to complex commercial litigation.

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