SEC Fines Meridian Financial RIA $75K for Marketing Rule Violations
Meridian Financial, LLC, a Massachusetts-based investment adviser with approximately $258 million in assets under management, has been censured and will pay a $75,000 civil penalty to settle charges brought by the U.S. Securities and Exchange Commission. The SEC’s action addresses multiple violations related to the firm’s marketing, recordkeeping, and compliance practices.
According to the SEC’s administrative order, Meridian Financial failed to comply with several key provisions of the Investment Advisers Act of 1940. The violations stemmed from a series of issues, most notably a claim made on the firm’s public website.
The SEC found that Meridian published an advertisement after the November 2022 compliance deadline for the new Marketing Rule, in which it stated that it “refuse[d] all conflicts of interest.” This claim was made without providing any context, even though the firm’s own documents, including its Form ADV brochure, acknowledged that it had conflicts of interest. The SEC determined that Meridian lacked a reasonable basis to substantiate this claim.
Under the Marketing Rule, registered investment advisers are prohibited from including in advertisements any material statement of fact that the adviser does not have a reasonable basis for believing it will be able to substantiate upon demand by the SEC. The Marketing Rule defines an advertisement as any “direct or indirect communication an investment adviser makes to more than one person … that offers the investment adviser’s investment advisory services with regard to securities to prospective clients … or offers new investment advisory services with regard to securities to current clients.”
The SEC has since released new guidance on the adviser marketing rule, specifically easing restrictions on the investment performance aspects of the rule, as previously reported by AltsWire in March 2025.
In addition to the marketing violation, the SEC also cited Meridian for recordkeeping failures and inadequate compliance policies.
According to the complaint, the firm failed to keep true, accurate, and current copies of all advertisements that appeared on its website, a requirement under the Advisers Act. Meridian relied on a third-party service provider to manage its website but did not have a contractual agreement in place to ensure these records were properly maintained.
Further, Meridian did not fully implement its own compliance policies and procedures. The firm allegedly failed to obtain a contractual undertaking from its third-party provider for recordkeeping and did not conduct a proper annual compliance review in 2023. The review it attempted was incomplete and assessed a stale version of the firm’s compliance manual.
Meridian Financial cooperated with the SEC investigation and has already undertaken several remedial steps. These include promptly removing the advertisement in question, hiring a third-party firm to assist with recordkeeping, and appointing a new chief compliance officer. In its settlement, Meridian has agreed to cease and desist from further violations and will pay the civil penalty in four installments. The firm consented to the findings without admitting or denying the allegations.
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