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ARTICLE · 22 OCTOBER 2026

FINRA Opens The Door To Projected Returns

K&L Gates
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On 15 October 2026, the Securities and Exchange Commission approved amendments to FINRA Rule 2210 that will permit broker-dealers to include projected performance and targeted returns in certain investor communications.1

United StatesFinance and Banking
Thoreau Bartmann
Thoreau Bartmann
Lance Dial
Lance Dial
Pamela A. Grossetti
Pamela A. Grossetti
Pablo Man
Pablo Man

On 15 October 2026, the Securities and Exchange Commission approved amendments to FINRA Rule 2210 that will permit broker-dealers to include projected performance and targeted returns in certain investor communications.1

Background and Implications

Rule 2210 historically prohibited broker-dealers from communicating projected performance or targeted returns, subject to narrow exceptions. This created particular difficulties for private fund managers that routinely use projected internal rates of return (IRRs), target multiples, and other forward-looking measures to explain investment opportunities. The prohibition also created a regulatory disconnect between FINRA Rule 2210 and Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (the “Marketing Rule”), which permits investment advisers to advertise projections and other forms of “hypothetical performance,” subject to specified conditions.

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