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Hiding the Ball: The Implications of the Marketing Rule

A recent order by the Commission in In the Matter of Wahed Invest, LLC, No. 3-22283 (Nov. 1, 2024) (the “Order”) issued against Wahed Invest LLP (“Wahed”) illustrates the operation of the Marketing Rule. Wahed, a financial services company based in New York, is subject to federal law and regulations, including the Investment Act, since it has been registered with the Commission as an investment adviser since 2015. On November 1, 2024, the Commission published a cease-and-desist order against Wahed for disseminating ads containing endorsements from professional athletes on its website, through emails, and on social media posts that failed to provide the disclosures required under the Marketing Rule.

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