Category Archives: Regulatory Risk Management
You’re probably already aware of SEC’s Modern Marketing Rule (Rule 206(4)-1), which replaces previous rules governing advertising by registered investment advisers, including asset managers and private funds.
You may even know these rules are scheduled to go into effect on November 4, 2022.
But does everyone in your firm who is involved in communicating with the public understand the new requirements? And, more importantly, is your firm on track toward meeting these requirements?
If you’re not, you’re not alone. According to Red Oak Compliance Solutions, less than 25% of their clients admit that they’ve fully instituted processes for complying with Rule 206(4)-1.
The good news is that most print and online marketing and advertising materials that asset managers produce already comply with SEC requirements.
However, the SEC’s new rules are designed to close certain loopholes, particularly concerning the way performance information is presented, as well as encompass the reality that messaging platforms like email and social media have become as important as pitchbooks, and web sites in conveying marketing and sales information to clients and prospects.
And, if that wasn’t enough, the SEC will now require asset managers to provide extensive documentation of the processes they used to create, review, approve and distribute advertising materials.
Is there a silver lining here? Perhaps, since the SEC is finally going to allow asset managers to use client testimonials and endorsements in their advertising.
Let’s take a closer look at the key provisions that will create the most work for asset managers—and what they need to do now to comply with the new rules.
The shift from active to passive investing continues to drive significant change for investment management sales and marketing. In this article, investment marketing consultants Sandra Powers Murphy and Donna DiMaria explain what marketers can do to help their firms grow AUM in today’s challenging environment.
According to DiMaria, operational efficiency in sales and marketing has become imperative, and asset managers are taking note.
“Firms are looking to be more efficient, doing more with fewer resources both in terms of bodies and budget. And that is leading to consolidation, outsourcing, and automation. The status quo isn’t working anymore so, in a way, the market is recreating itself,” she said.
Asset Managers are heavily focused on bringing in new business and attracting the right clientele. Compliance, while important, is something you’d prefer to have running smoothly in the background rather than disrupting your day-to-day flow.
However, an increase in hefty fines throughout the asset management industry means compliance needs to be front-and-center. To make the most of your resources and to ensure you’re not caught by surprise when regulators review your materials, you need to ensure you’ve built efficient, compliant processes that are easy for your team to understand and comply with.
One particular pain point we’ve heard about from clients: keeping sales team collateral up to date and books and records compliant across an organization.
When meeting and consulting with clients, most investment data specialists refer to 5 datasets managers need to populate in their investment database profiles:
Performance, AUM, Holdings, Characteristics, and Personnel. These are the quantitative datasets. And yes, they are each very important.
However, we at APX Stream believe there are, in fact, 7-9 datasets for which managers need to account. These additional datasets include the qualitative narrative sets: Firm & Product Narratives, Firm & Product Personnel.
But it’s not simply a matter of checking these items off a list every quarter – to successfully execute a professional investment data marketing strategy, managers need to understand, not only the range of data points contained within each set, and account for them accordingly, but how they all work together to create a cohesive, data-driven story for your firm.
All the pieces must fit, and do so in a way that entices database subscribers (i.e. your future clients & investors) to pick up the phone or dash off an email inquiring about your portfolio management services.
So how should these pieces fit together and what are some ideas managers can employ to help improve their data marketing execution?