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Vedder Thinking | Articles Compliance Date for SEC’s Marketing Rule – November 4, 2022


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On March 5, 2021, the U.S. Securities and Exchange Commission’s new “Marketing Rule,” which overhauls the Investment Advertising Rule under Rule 206(4)-1 and the Cash Solicitation Rule under Rule 206(4)-3 under the Investment Advisers Act of 1940, was published in the Federal Register. The Marketing Rule becomes effective on May 4, 2021. Following an 18-month transition period, the compliance date will be November 4, 2022.

The new Marketing Rule represents a significant change to investment adviser practices with respect to advertising, cash solicitation and recordkeeping. Investment advisers will need to adopt new policies and procedures to comply with the Marketing Rule. Please see our analysis on the Marketing Rule found here.

Vedder Price recently hosted a webinar panel discussion about the new Marketing Rule, which featured Joseph M. Mannon and Robert M. Crea of Vedder Price, as well as Julie Dixon, Founder and CEO of Titan Regulation, as panelists. A full recording of the webinar, entitled Impacts of the SEC’s Updates to the Advertising and Cash Solicitation Rules, may be viewed below.


Impacts of the SEC’s Updates to the Advertising and Cash Solicitation Rules from Vedder Price on Vimeo.


Robert M. Crea


Joseph M. Mannon