ADISA submitted comments to FINRA regarding its proposed communications rule change, saying the proposed rule change to permit “institutional communications” and communications regarding QP-only funds to include projections of performance or targeted returns a “small, but condition-laden step in the right direction.” FINRA’s 230-page proposal would allow the use of predicted returns in marketing and would apply to brokers dealing with institutions and investors possessing assets over $5 million. Under the proposal, eligible recipients are referred to as “‘Projection-Eligible Investors.”

The letter was drafted by ADISA Legislative & Regulatory Co-Chairs John Grady, ABR Dynamic Funds, and Catherine Bowman, The Bowman Law Firm, and was signed by ADISA President Michael Underhill, Capital Innovations.

Read the letter in its entirety here.