The Securities and Exchange Commission today published a
According to the SEC’s staff, an incidental mention of a specific investment company or family of funds not related to a discussion of the funds’ investments need not be filed with Financial Industry Regulatory Authority.
For example: “Fund X Family of Funds invites you to their annual benefit for XYZ Charity” or “More than 100 Fund X employees volunteered for our Annual Day of Caring!”
Also, the incidental use of the word “performance” in connection with a discussion of an investment company or family of funds, without specific mention of a fund’s return (i.e., 1, 5 and 10 year performance) is also kosher, according to the SEC’s latest guidelines. For example: “We update the performance of our funds every month and publish the results on
“Today’s inaugural IM Guidance Update on social media is intended to help firms strengthen their compliance efforts by providing meaningful real life examples in a format that is accessible to all on the SEC’s website,” stated Norm Champ, Director of the Division of Investment Management.