Comprehensive Client Disclosure Document Services
As the number of regulatory enforcement actions continue to rise, client disclosure documents are being scrutinized more closely by regulatory authorities than ever before. At Jacko Law Group, PC (“JLG”) we offer a full range of proactive services designed to provide you with comprehensive and comprehensible client disclosure documents based on information relayed to you, so that your clients can make informed decisions.
Our firm and professional staff draft and review client disclosure documents in conformance with various legislative acts, including the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, Investment Company Act of 1940 and FINRA regulations, as applicable.
After evaluating existing client disclosure documents, we provide recommendations on how you may wish to enhance them.
We draft, evaluate & revise:
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- Form ADV Part 2
- Client agreements
- New account forms & investment policy statements
- Offering documents
- Private placement memorandums
- Performance
- Advertising & sales literature disclosures
- Performance marketing materials
- Response to request for proposals (RFPs) & questionnaires
- Wrap fee program client documents
- Mutual fund client documents
- Hedge fund client documents
- Financial plan documents
- Quarterly performance reports
- Monthly/quarterly invoice statements
- Section 408(b)(2) disclosures
Performance Advertising Disclosures
Effective November 4, 2022, SEC registrants will need to comply with the New Marketing Rule. It will, for the first time, permit investment advisers to include client testimonials, including reviews and referrals, within electronic media outlets. It also will change the way that firms present performance and disclose the use of solicitors. For some firms, this will materially impact their current advertising and sales practices. It will also necessitate advisory firms to update existing policies and procedures, redraft solicitor agreements, and develop new internal controls.
At Jacko Law Group, PC (“JLG”) our counsel has years of experience in developing disclosures in accordance with performance advertising regulations. We help firms understand the “dos and don’ts” of marketing, and provide disclosures based on regulatory guidance and best practices.
Our securities attorneys are nationally recognized in the area of performance advertising compliance. Our Firm Managing Partner, Michelle L. Jacko, gives frequent lectures on performance advertising, and has been published several times on this subject.
JLG can review your client marketing collateral, social media, firm advertisements and solicitor arrangements in accordance with the Investment Advisers Act of 1940 and the revised Rule 206(4)-1, as well as the Global Investment Performance Standards (GIPS) as applicable. Our professionals have years of experience in performing advertising and marketing reviews and are ready to help.