Investment advisers, and therefore fund managers once they register as investment advisers, are limited in how they advertise. Section 206 of the Investment Advisers Act already prohibits fraud, deception or manipulation, regardless of whether the fund manager is registered. Once registered, Rule 206(4)-1 imposes additional restrictions on advertising that the SEC has determined would be [...]
Tag Archives: testimonials
Client Lists and Private Fund Managers
Section 206 of the Investment Advisers Act prohibits fraud, deception or manipulation, regardless of whether the fund manager is registered. Once registered, Rule 206(4)-1 imposes additional restrictions on advertising that the SEC has determined would be fraudulent deceptive or manipulative. The first item on the list of restrictions is testimonials. This prohibition reflects the concern [...]
FTC Guidelines Are In Effect
Today is a the day. The FTC’s recent updates to its Guides Concerning the Use of Endorsements and Testimonials in Advertising are now in affect. To comply with the Guides, individuals (bloggers, users of social media) must disclose every “material connection” or relationship they have with an advertiser. How to comply with the changes? Disclose [...]
Compliance and Recommendations on Social Networking Sites
I am an enthusiast of social networking sites and web 2.0. But I realize they have limitations and dangers. I have been very concerned about the Recommendations feature in LinkedIn. That feature allows any of your connections on LinkedIn to post a recommendation or endorsement about you that appears on your profile page. At first, [...]
Social Media
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