Model Rules July 29, 2025

NASAA Seeks Public Comment on Proposed IA Advertising Rule Amendments

The North American Securities Administrators Association (NASAA) released proposed amendments to its model investment adviser advertising rules on July 29, 2025, seeking public comment with a deadline of August 28, 2025.

The proposed changes aim to harmonize state advertising requirements with the SEC Marketing Rule (Rule 206(4)-1), which took effect on November 4, 2022. Most states had their own advertising rules that predated the SEC's overhaul.

Key areas addressed in the proposal include updated provisions for testimonials and endorsements, performance presentation standards, third-party ratings disclosures, and requirements for digital and social media communications.

NASAA's membership subsequently voted to adopt the amendments on May 4, 2026. As model rules, the amendments take effect in a given state only after that state adopts implementing changes; Texas had already adopted the SEC Marketing Rule by reference in March 2025.

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