Investment Management Developments

In late 2010, the Securities and Exchange Commission (the SEC or the Commission) sent a “sweep” letter (the Sweep Letter) to a number of registered investment advisers requesting information on  their involvement with social media and related recordkeeping practices. The Sweep Letter appears to signal heightened regulatory awareness that social media websites such as Facebook and  LinkedIn are increasingly being used by investment advisers to connect with clients. Use of these sites may present regulatory issues under the advertising rules of the Investment Advisers Act of 1940  (the Advisers Act).