SEC Marketing Rule compliance with every claim proven to its record before a principal signs
Every claim proven to its record, every local version checked, approved the same day.
See one case, screen by screen ↓SEC Marketing Rule Compliance is marketing compliance software for the review that keeps every investment adviser advertisement within Rule 206(4)-1, the investment adviser marketing rule, and every fund communication a broker-dealer distributes within FINRA Rule 2210. It puts the factsheet or pitch book on the screen with a sticker on every claim, and seven agents prove each figure to its record, recompute net of fees, insert approved disclosures and check local versions, for the reviewer to decide and a registered principal to approve.
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SEC Marketing Rule compliance means every adviser advertisement meets Rule 206(4)-1, and every fund communication a broker-dealer distributes also meets FINRA Rule 2210. In the quarter-end factsheet wave, a marketing compliance reviewer reads each factsheet, one-pager and pitch book with a highlighter, emails the performance team for the record behind each number, checks that net of fees sits beside gross with equal prominence, pastes disclosures from a Word file and chases a registered principal for a signature. Local-language versions are translated after the English master is approved and are rarely re-checked line by line.
Fund communications a broker-dealer distributes go through a FINRA advertising review as well. The risk sits in the claims nobody had time to prove: a gross-only headline return, a stale quarter, an extracted result that is really a list of the best contributors, a backtest on a public web page, a ranking without its date, period, provider and fee, a translator's "low risk" that the English master never said. When the SEC asks for an advertisement, the ad, the approval email, the performance spreadsheet and the disclosure version sit in four different systems.
Estimated elapsed hours for a routine factsheet or one-pager, by hand and with the solution.
Seven agents sticker, prove, disclose and check every claim; the reviewer decides, a registered principal approves.
Tuesday, July 14, 2026, the Q2 factsheet wave at Quillfield Capital: 612 pieces since July 1, 386 in review, 64 due today. At 10:28 a.m. Leah Whitford submits the Global Equity Strategy institutional one-pager. The reviewer works with the agents in plain words, sees the record behind every claim and decides; a registered principal approves. Here is what happens next, screen by screen, in the working solution.
Priya's Today screen shows 23 pieces waiting for her, 3 due before noon; across the team, 64 are due today, 7 are over the service level and 341 are already checked by agents. Each item under Needs you has one next step: open the Global Equity one-pager, review a blocked website backtest, answer a FINRA comment letter. Beside it the agents report what they did overnight, and she asks them in plain words, such as which pieces are over their service level or which live pieces are stale. Every answer cites the record.
Second Review agent: “I disagree with the Substantiation agent on one claim today: the ‘Top 10 holdings’ line on MR-26-04187. Both arguments are on the sticker.”
The Intake agent reads the one-pager and its distribution list: an advertisement under Rule 206(4)-1, an institutional communication under FINRA Rule 2210 with no filing, principal approval by firm policy FP-1, risk tier High because it carries backtested performance, due at 2:00 p.m. It shows why, with 97% confidence, and the reviewer can correct the classification. A one-on-one RFP response is marked not an advertisement, with its hypothetical section still in scope.
The Intake agent never decides a piece is not an advertisement without showing the exclusion it relies on.
The piece itself is the screen. Fourteen numbered stickers sit on its claims: the headline return, the annualized table, the benchmark, a ranking, a testimonial, a superlative, extracted performance, a backtest, carbon intensity, firm AUM, strategy assets, the legend, the periods and a missing fee footnote. The status bar reads 14 claims, 5 proven, 6 agent fixes to check, 3 open. Sticker 1 is red: +14.2% one year, gross of fees, with no net beside it.
For the selected sticker: the rule it triggers, the record that proves it, the disclosure it still needs.
Priya opens the record behind sticker 1. The source drawer shows the performance system's composite GEQ-01: 12 monthly returns, July 2025 to June 2026, gross 14.21% and net of the model fee 13.41%, with the 0.70% fee deducted monthly, 37 accounts, last updated July 9 by Owen Byrne. Under it sit the rule it triggers, Rule 206(4)-1(d)(1), and the fee footnote DL-PERF-07 v3 from the disclosure library.
“Read-only copies of the records; the record itself stays in its system.”
Rule 206(4)-1(d)(1) wants net performance beside gross with at least equal prominence, for the same period and method. One click on Insert net of fees: the Substantiation agent recomputes from the 12 monthly returns, and the Disclosure agent inserts “+13.4% net of fees” at the same size as the gross figure, with the fee footnote linked. The sticker turns amber, fixed by agents and waiting for Priya to accept it.
The Substantiation agent never marks a claim proven without an exact record match, within 0.05 point.
“Top 10 holdings returned +31.6% over 12 months.” The Substantiation agent says the figure is correct and could stay as extracted performance with the total portfolio, gross and net, beside it. The Second Review agent, re-reading the piece blind on a separate model, says those are the ten best contributors, not the ten largest holdings, which returned +17.9%: selected results, not fair and balanced. Priya reads both arguments and removes the line with reason code FB-2.
The Second Review agent never resolves a disagreement itself.
Beside the proof sheet is a conversation with the agents about this piece. Asked where $912 billion comes from, the Substantiation agent answers that no record says $912 billion: firm AUM at June 30, 2026 is $902.4 billion, and the extra $9.6 billion is model-delivery assets the firm does not manage, which policy FP-2 allows only with a disclosure. It corrected the figure, and the answer links its record.
“Best-in-class risk management” has no record behind it, and “best” is a restricted word under firm policy FP-4. Priya sends two rewrites to Leah. In her own view, Leah sees the request in plain words and picks “A risk process with three independent checks on every portfolio”, which risk policy RP-2 page 4 supports. She can also run the same pre-check on her next draft before she submits it.
Authors choose wording; they never approve.
The Global Equity Fund UCITS factsheet has German, French, Italian, Spanish, Dutch and Portuguese versions: 412 lines against the approved English master. Every figure and date matches. German line 7 says “mit geringem Risiko”, with low risk, where the master says “risk-managed approach” and the KID shows risk class 4 of 7. A new claim in translation is always a finding, so it goes to Tomás Ferreira, the EMEA reviewer.
At 11:01 Priya marks the review prepared, attesting that she reviewed every claim and its record. Dana sees the prepared review: what the reviewer decided on each open claim, the 5 claims the agents proved to an exact record, the proof pack and the duties check, which confirms three different people and no agent approval. She approves at 11:05. The piece is released to the consultant portal and sales library, the records pack is sealed for 6 years and expiry is set to October 9, 2026, when Q3 returns land.
Nothing is released without the preparer's and the approver's names.
The same one-pager, seen by the four people who carry it: what the quarter-end wave looked like, and what it looks like now.
Seven agents sticker, prove, disclose and check every claim; the reviewer decides, a registered principal approves.
Classifies each submission: type, channel, audience, jurisdiction, the rules that apply, whether a FINRA filing is needed and its clock, the risk tier, the service level and the reviewer.
Stickers every claim on every page: performance, hypothetical, extracted, characteristics, ratings, awards, testimonials, endorsements, superlatives, ESG, firm facts and missing legends.
Pulls the record behind each claim from the performance system, portfolio accounting, index and ESG feeds, the consultant database, the CRM and Form ADV, and recomputes net of fees, the periods, benchmarks, ratings, AUM and characteristics.
Inserts the required disclosure from the firm's approved disclosure library, at the right size and place, with its ID and version.
Re-checks the whole piece blind, on a separate model, and escalates every disagreement to the reviewer with both arguments.
Compares each local-language version with the approved English master line by line: figures, dates, meaning and the required local legends.
Seals the records pack, builds FINRA filing packages and tracks their clocks, sets expiry and watches live pieces for stale returns and expired ratings.
Decide, approve, govern. The agents propose; a named person decides.
Ask the agents about a piece, a sticker, a rule or a local version, or tell them what to do. Every answer cites the record it came from.
Why is the one-year figure on the Global Equity one-pager red?
It shows +14.2% gross with no net figure of equal prominence, which Rule 206(4)-1(d)(1) requires. Composite GEQ-01 gives 13.4% net of the 0.70% model fee for the same 12 months to June 30, 2026. One click inserts it.
Why do the agents disagree on the top 10?
The box says “Top 10 holdings” but lists the ten best contributors (+31.6%), not the ten largest holdings, which returned +17.9%. The Substantiation agent says it could stay as extracted performance with the total portfolio beside it; the Second Review agent says it is selected results and not fair and balanced. You decide.
Which pieces carry hypothetical performance today?
Two. The Global Equity one-pager passes: its audience is institutional and policy HP v3 allows it, with disclosure DL-HYPO-03 inserted. MR-26-04173, the Multi-Asset Income website page, is blocked: hypothetical performance on a public page is what most of the SEC's 17 Marketing Rule cases were about.
Which live pieces are stale?
Q2 returns were published July 9. 318 live pieces still show Q1 2026 returns; refreshes are drafted for 112 and 206 wait on their Q2 records. Under policy EX v1 they expire July 31.
13 screens from the working solution, on its sample data. Pick one to see it large.
Service levels, thresholds, residency and retention are settings. The administrator changes them; the CCO approves every agent and model change.
| Setting | Default | Choose from |
|---|---|---|
| Service level, risk tier High | 1 business day, with principal and second-reviewer sampling of 10% | Set per tier: High (hypothetical, private funds, paid testimonials) · Standard · Social posts |
| Service level, Standard and social | 2 business days · social posts the same day, 4 hours | Set per tier by the administrator |
| Escalation | To the CCO after 2 business days over | Reminders to authors at 24 hours |
| Proven by an agent | Confidence 0.95 with an exact record match, within 0.05 point | Thresholds are set per agent and version; changes need the CCO |
| Intake classification | Below 0.90 confidence, a person classifies | Thresholds are set per agent and version; changes need the CCO |
| Expiry of live pieces | Policy EX v1: 21 days after the next quarter's returns | Firm policy, changed by proposal and CCO approval |
| Data residency | US material in US East, EU and UK in EU West, APAC in Singapore | Per region; EU material never leaves the EU |
| Retention | Records packs 6 years from last use, write-once | Legal holds override retention |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (Lowenstein Sandler on SEC actions under the Marketing Rule since November 4, 2022 — 17 advisers, about $2.3 million; FINRA Rule 2210(c) on filing investment company retail communications within 10 business days of first use; SEC Rule 206(4)-1). Quillfield Capital, its funds and the people named on this page are fictional — characters and sample data in the working solution.
SEC Marketing Rule Compliance is marketing compliance software for the review that keeps every investment adviser advertisement within Rule 206(4)-1, the investment adviser marketing rule, and every fund communication a broker-dealer distributes within FINRA Rule 2210. It puts the factsheet or pitch book on the screen with a sticker on every claim, and seven agents prove each figure to its record, recompute net of fees, insert approved disclosures and check local versions, for the reviewer to decide and a registered principal to approve.
Yes. Rule 206(4)-1(d)(1) sets the net of fees performance advertising requirement: net beside gross, with at least equal prominence. When a piece shows gross performance, the Substantiation agent recomputes net of fees from the composite's monthly returns for the same period and method, and the Disclosure agent proposes inserting it at the same size with the fee footnote from the library. The reviewer accepts it. The 1, 5 and 10-year periods are checked against the latest record too.
Backtests, model results and targets are stickered as hypothetical and tested against the firm's hypothetical performance policy for the intended audience. In the working solution, a backtest in an institutional one-pager passes with its criteria, assumptions and risks inserted from the library, while a website page with hypothetical performance is blocked before release.
Yes. For SEC Marketing Rule testimonials and endorsements, each testimonial is matched to its consent in the CRM, with compensation and conflicts disclosed; a paid promoter without a written agreement on file is an open finding. A ranking is matched to its row in the consultant database, with the date, period, provider and any fee disclosed.
Yes. The FINRA 2210 review starts at intake: the Intake agent decides whether a piece needs filing and starts its clock, such as 10 business days after first use for investment company retail communications. The FINRA filings screen shows each due date and status, builds the filing package and holds the comment letters with their drafted answers.
Yes. The Language Compare agent compares each local version with the approved English master line by line, for figures, dates, meaning and the required local legends under the ESMA guidelines and local rules. A new claim in translation is always a finding for the local reviewer, and it never approves a local version.
Yes. The agents propose; the reviewer accepts, edits or rejects every finding with a reason code, the author chooses wording, and a registered principal approves. The author, preparer and approver must be three different people, agents never approve, and every action is on an append-only audit trail.
The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your marketing policies, disclosure library and a sample of past pieces, and it goes live once every quality gate has passed. In the working solution, first-time setup ran the agents on 400 past pieces that people reviewed in 2025, with their known findings, before it went live region by region.
Mandate rules live in a day, not two weeks, each read twice, tested and cited.
1-min demoInvestment Guideline MonitoringOf 412 overnight alerts, 9 reach a person, and every close cites its clause and approver.
1-min demoTrade SurveillanceEvery alert closed with a cited case file, and a second reviewer on every close.
1-min demoWe'll run SEC Marketing Rule Compliance on a sample of your own approved and returned pieces.