Proposed Amendments to Investment Adviser Advertising and Solicitation Rules: Practical Implications for Private Fund Sponsors
The Securities and Exchange Commission (the “SEC”) recently proposed amendments (the “Proposed Amendments”) to Rule 206(4)-1 (the “Advertising Rule”) and Rule 206(4)-3 (the “Solicitation Rule”) under the Investment Advisers Act of 1940 (the “Advisers Act”). This memorandum summarizes the proposal and analyzes the practical impact the Proposed Amendments, if adopted, would have on registered investment advisers that sponsor private funds.