The SEC announced a settled action against Meridian Financial, LLC (Meridian) for failures under the Investment Advisers Act concerning marketing, record-keeping, and compliance requirements. Meridian disseminated a website advertisement in which it claimed it “refuse[d] all conflicts of interest” without providing any context for this claim. This statement contradicted disclosure in the firm's Form ADV Part 2A related to its conflicts of interest. As such, the SEC found that Meridian violated the requirement under Rule 206(4)-1 (the Marketing Rule) that the adviser have a reasonable basis to believe that it would be able to substantiate such a claim in its advertisement upon demand by SEC staff. The firm was also charged with failing to maintain copies of all advertisements, including those that appeared on its website, in violation of Rule 204-2 (the Books and Records Rule). Finally, the firm was charged with not conducting a comprehensive annual compliance review, in violation of Rule 206(4)-7 (the Compliance Rule). In one year, the annual review was limited to a cursory review of the firm's Form ADV. In the next year, the firm engaged a compliance consultant to conduct the review, but the consultant assessed a stale version of the compliance manual that did not incorporate the requirements of the amended Marketing Rule. Meridian received a significant penalty despite the small size of the firm. This case underscores the importance of being able to substantiate statements in advertisements, appointing a competent CCO, establishing and maintaining a robust compliance program that reflects the dynamic requirements under the Advisers Act, and regularly reviewing and testing for compliance, either internally and/or with the assistance of competent compliance consultants.