← All rule pagesRule 206(4)-1(a)(3)
General prohibition: misleading implications or inferences
misleading-implicationgeneral-prohibition
Verbatim from the rule
An advertisement may not include information that would reasonably be likely to cause an untrue or misleading implication or inference to be drawn concerning a material fact relating to the investment adviser.
What violations look like
LinkedIn
Our team has decades of combined Wall Street experience.
Why it's flagged: "Combined experience" is the classic dodge — three advisers with five years each is fifteen years combined, but the phrasing reads as deep individual expertise. The literal claim is true; the implication misleads.
Compliant rewrite
Our advisers each have five years of investment-management experience.
Website
Backed by a global investment team.
Why it's flagged: If "global" actually means two analysts in different time zones rather than offices on multiple continents with local market expertise, the implication of international depth misleads even though no single word is false.
Compliant rewrite
Substantiate or drop the word: "Our two-person research team coordinates US and EMEA market coverage."
Pitch deck
$2 billion under our advisement.
Why it's flagged: If a meaningful chunk is custodied-only or brokerage assets — not under fee-for-advice — this implies a fee-managed AUM that isn’t real. Form ADV Item 5 distinguishes regulatory AUM from advisory AUM precisely so this kind of implication can’t be made.
Compliant rewrite
$700M in regulatory assets under management; $1.3B in custodied client assets. As of December 31, 2025.
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