SEC Division of Examinations Shares Further Observations on Marketing Rule Compliance
National Law Review
AFS attorneys Jon Jurva, Vanessa Meeks, and Kendall Murphy provide an overview of the SEC Division of Examinations’ December 16, 2025 risk alert addressing advisers’ compliance with the Advisers Act Marketing Rule, with a focus on testimonials, endorsements, and third party ratings.
The National Law Review recently republished an alert by partner Jon Jurva, counsel Vanessa Meeks, and associate Kendall Murphy. In their alert they summarize the Division’s latest observations on the Marketing Rule, highlighting widespread deficiencies in disclosures, oversight of promoters, and the use of third‑party ratings. Key issues include unclear or omitted disclosures, inadequate agreements and due diligence, misuse of exemptions, and failures to verify promoter eligibility. Jon, Vanessa, and Kendall also note gaps in policies, procedures, and implementation across websites, social media, and referral programs.
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