Rule 206(4)‑1 (Marketing Rule or Rule) under the Investment Advisers Act of 1940 was adopted in December 2020 and took effect in November 2022. More than three years later, many advisers continue to face challenges in complying with the Rule. To date, most SEC guidance on the Rule has been in the form of frequently asked questions (FAQs) issued by the SEC’s Division of Investment Management (Division), which focus on presentation of performance, and most enforcement actions have involved hypothetical performance. The latest developments as to the Marketing Rule were covered in a program featuring Dechert partners Michael W. McGrath, Lindsay R. Grossman and Robert S.H. Shapiro; CFA Institute director Ken Robinson; and Scott Jameson, senior counsel in the Division’s Chief Counsel’s Office. This article examines key takeaways from the program, including the ongoing challenges raised by footnote 590 of the Rule’s adopting release; the impact of the Division staff’s FAQs that were released on January 15, 2026; issues around presentation of case studies and hypothetical performance; and FINRA’s proposal to loosen its prohibition on projecting returns. See “Marketing Rule Risk Alert Focuses on Testimonials, Endorsements and Third‑Party Ratings” (Mar. 5, 2026); and “Performance Reporting Templates, Standards and Initiatives for PE and Real Estate Funds” (Feb. 5, 2026).