Can an adviser publicly disclose recommendations less than a year old if they include an entire year? Or does the entire slate of recommendations have to be older than a year?
For example, if an adviser today discloses all of its recommendations since 8/17/22, would that be legal?
The wording in the section is:
Investment advisers and IARs may disclose their recommendations publicly if they disclose all recommendations over a specific time period of at least a year. For example, an adviser may post all recommendations they made in 2019 given it’s been at least one full year since those recommendations have been made.
That sort of implies that an entire year must elapse before disclosing a recommendation.