On December 16, 2025, the Securities and Exchange Commission’s (“SEC“) Division of Examinations issued a Risk Alert highlighting several recurring deficiencies in investment advisers’ compliance with the provisions of Advisers Act Rule 206(4)-1 (the “Marketing Rule”) governing use of testimonials and endorsements as well as third-party ratings. These observations serve as useful reminders of the basic compliance expectations that advisers must continue to uphold. The tone of the Risk Alert is consistent with the SEC’s 2026 Exam Priorities, which emphasize a continued focus on foundational requirements of the Advisers Act.
