The SEC’s recent enforcement action serves as a reminder that the Marketing Rule extends well beyond performance results and testimonials. On September 4, 2025, the Commission announced its first Marketing Rule case under newly appointed Chair Paul Atkins, charging Meridian Financial, LLC for statements on its website that claimed the firm refused all conflicts of interest. However, the firm’s own Form ADV disclosed several such conflicts.
The SEC concluded that Meridian lacked a reasonable basis to support its marketing claim—a violation of Rule 206(4)-1(a)(2)—and also cited recordkeeping and compliance program failures under the Investment Advisers Act of 1940. Although Meridian primarily advised individuals, the issues identified apply equally to private fund advisers and institutional managers. The firm agreed to a $75,000 civil penalty.
To help you make sense of what this means for you and your client, read full article from our friends at SEC3 here.
