The U.S. Securities and Exchange Commission (SEC) announced on September 11, 2023, settlement agreements with nine registered investment advisers. All were charged with advertising hypothetical performance on their websites without adopting and implementing policies and procedures required by Rule 206(4)-1 (the Marketing Rule) under the Investment Advisers Act of 1940 (Advisers Act).

Robert Kim
Robert Kim is an associate in the Investment Management practice. Prior to joining Perkins Coie, Robert advised insurance company clients on federal and state securities law, broker-dealer regulations, insurance laws, and rules for summary prospectus and selling of variable contracts.
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