Firm Wire items are announcements made by the firms themselves. The desk confirms that the announcement was published and reproduces its factual content. It does not verify the claims in it, and publication is not an endorsement.
Sidley says it published an update on broker-dealer performance communications
Sidley said it published an update on approved FINRA rule changes concerning projected performance and targeted returns in broker-dealer communications. The firm’s article examines conditions for using the new exception, its limits and the compliance steps relevant to private fund sponsors, distributors and dual registrants.
Key points
- Sidley’s update discusses written policies for identifying the intended audience.Sidley
- The firm’s article examines disclosure and recordkeeping requirements.Sidley
- Sidley’s analysis distinguishes projected returns from backtested, model, related and extracted performance.Sidley
- The firm’s publication considers how broker-dealer standards interact with investment adviser marketing requirements.Sidley