We comply with all advertising rules promulgated under the Investment Advisers Act (IAA) and issued by the Financial Industry Regulatory Authority (FINRA). Our internal policies articulate guidelines and review processes to ensure that all communications are clear, accurate, and fair and balanced, in compliance with applicable standards.
In addition to conforming to the regulations defined by the IAA and FINRA, all materials are reviewed and approved in advance of publication. These include the following:
- Any written communication addressed to more than one person
- Any published or broadcast notice
- Any analysis or report concerning securities distributed to more than one person
- Any graph, chart, formula or other device used to solicit the purchase or sale of a security or that offers any other investment advisory service related to securities
Our product distribution teams are staffed with people who are licensed through FINRA and undergo extensive background checks. We endeavor to ensure that our sales force is educated, competent and ethical. Each is held to our Code of Business Conduct and Ethics Policy.
Victory Capital has policies and procedures in place regarding the Investing and Retention of Qualifying Employer Securities, and Transactions Involving Parties in Interest. It is the policy of Victory Capital to monitor transactions in employee benefit accounts defined in Section 3(2)(A) of ERISA to ensure we properly invest on behalf of benefit plan investors.
