This sample checklist provides some guiding principles for an investment adviser firm that is considering the use of case studies in advertising.
RCC is in no way recommending the use of case studies and offers no assurances that a case study will be treated as acceptable advertising by a securities regulator. Whether an advertisement is viewed as misleading depends upon both full text of the advertisement and the context of its use. The following guiding principles are not a substitute for or the same as a review by a compliance consultant at RCC. There are issues that a compliance consultant may identify that are not addressed by these guiding principles.
This sample form should be considered as a starting point; the investment adviser firm will need to customize this sample form to its business model and policies and procedures. Please see our disclosure about the limitations of sample form at http://www.ria-compliance-consultants.com/ria_express_investment_advisor_compliance_tools/sample-forms/
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This sample document is not intended to detect or prevent fraud, selling away, Ponzi schemes, undisclosed outside business activities, inaccurate or false fee calculations, theft, misappropriation or unlawful conversion of client funds.
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