SEC marketing rule reminder for fund outbound mail

This bulletin applies to US-registered investment advisers (RIAs) and exempt reporting advisers using Finmail for investor-facing email.

Before bulk investor updates

1. Review content — Confirm performance claims, testimonials, and forward-looking statements meet SEC Marketing Rule (Rule 206(4)-1) requirements for your firm.
2. Secure Share settings — When distributing sensitive documents, use Finmail Secure Share with burn-after-read and access badges; verify recipients before sending.
3. Audit trail — Ensure compliance officer roles can access compliance_audit_logs for send, download, and secure-link events relevant to the campaign.
4. Team shared outbound — Mail merge and linked send-as identities require Team or Enterprise; verify the sending identity matches your ADV disclosures.

Finmail controls that help

• Append-only CM6 audit chain for high-risk actions (open, download, forward, secure link).
• Privacy gateway header scrubbing and tracking-pixel neutralization on outbound HTML.
• Auto-BCC to compliance archive when all recipients are external (Team+ configuration).

Questions

Contact your compliance lead or [email protected] for architecture evidence. For enterprise Legal Hold or examiner packages, email [email protected].

See also the Security Trust Center and online security whitepaper.