SEC Sanctions Investment Adviser for Marketing Rule, Books-and-Records, and Compliance Violations

On September 4, 2025, the SEC issued an order against Meridian Financial, LLC, for violations of the Advisers Act. The SEC found that Meridian violated the marketing rule by falsely claiming on its website that it “refuse[d] all conflicts of interest,” a claim unsupported by evidence and contradicted by its own Form ADV. 

The SEC also determined that Meridian failed to maintain accurate records of its website advertisements, violating the books-and-records rule. Furthermore, Meridian violated the compliance rule by conducting inadequate annual reviews of its policies and procedures in 2023 and 2024. 

Meridian was charged with violating Advisers Act Sections 204(a) and 206(4), and Rules 204-2(a)(11), 206(4)-1(a), and 206(4)-7. The firm agreed to pay a $75,000 penalty and implement corrective measures. 

Key Takeaways for Investment Advisers and Broker-Dealers: 

  • Ensure all marketing claims are substantiated and consistent with Form ADV disclosures. 
  • Maintain comprehensive marketing archives, including website versions and removed claims. 
  • Update compliance manuals to reflect current marketing rule requirements and actual firm practices. 
  • Conduct meaningful and well-documented annual compliance reviews with real compliance testing. 

 

For an in-depth review of this and a complete analysis of all regulatory updates in the third quarter of 2025, please download our Regulatory Update. 

If you require any assistance in ensuring your firm is compliant with the amendments or need assistance with implementation, contact LawVisory.   

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Jeffrey Smith

Jeffrey Smith, JD. is the Managing Attorney at LawVisory, specializing in SEC compliance, privacy regulation, and regulatory risk management for RIAs, broker-dealers, and fintech innovators. With over a decade of experience advising regulated entities, Jeff helps firms operationalize compliance through actionable frameworks and evidence-based readiness programs. 

Attorney Advertising—LawVisory PLLC is a U.S. law firm and provides this information as a service to clients, prospective clients, and other friends for educational purposes only. It should not be construed or relied on as legal advice or to create a lawyer-client relationship.

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