In another Marketing Rule case, the SEC charged investment adviser Atlas Financial Advisors, Inc. with violations of Rule 206(4)-1 under the Investment Advisers Act. Atlas allegedly made false and misleading claims about its investment strategies and their performance, failed to present net performance information alongside gross performance, was unable to substantiate performance claims upon demand by the Commission, and advertised hypothetical performance on its public website without adopting and implementing required policies and procedures. The firm was further charged with violations of the Compliance Rule and Books and Records Rule and agreed to a $175,000 settlement in addition to other remedial actions. Investment advisers are encouraged to review this case in connection with their marketing practices and proactively review and, if needed, update policies, procedures, and marketing materials and ensure supporting documentation is maintained and available for SEC examiners.