On November 4, 2019, the SEC proposed substantial updates that in many respects reformulate the rules governing investment adviser advertising and referral arrangements. Together, these rules go to the heart of how SEC-registered investment advisers obtain and retain clients and investors. We are still digesting the 508-page release and expect to provide a more detailed analysis over the coming weeks, but following are some initial highlights.

This client alert provides a factual summary of the more significant elements of the rule proposal and is designed to assist clients who might not yet have had time to review the proposal in detail. There are a number of areas that merit further analysis, discussion and comment.

We encourage clients to reach out to us as they evaluate the impact of these proposals on their business and consider commenting on the proposal. Comments are due within 60 days of publication in the Federal Register.

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