SEC Issues IM Guidance Update on Testimonial Rule and Social Media

The SEC issued an Investment Management ("IM") Guidance Update regarding the application of Investment Advisers Act Section 206(4) and Rule 206(4)-1(a)(1) (the "testimonial rule"), which generally prohibits investment advisers from using testimonials in their advertisements. The Guidance answers questions concerning investment advisers' use of social media and discusses the situations in which investment advisers may tout their "likes."

See: SEC IM Guidance Update.