Morgan Lewis

SEC Staff Permit More Flexibility in the Use of Past Specific Recommendations

By Monica Lea Parry, Jennifer L. Klass, Steven W. Stone, Thomas S. Harman, Investment Management Practice

LawFlash/Client Alert

  • published on:

    12/18/2008
  • by:

    Investment Management Practice

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As many are now aware, the Securities and Exchange Commission (SEC) staff recently issued a no-action letter to The TCW Group, Inc. (TCW Group) liberalizing its previous interpretive positions on the use of past specific recommendations in investment adviser advertising. This FYI summarizes the no-action letter and discusses certain issues that investment advisers may wish to consider before taking advantage of this additional flexibility in the use of past specific recommendations.

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