Hedge Fund Website: What the SEC Lets You Say

Most hedge fund websites look almost empty: a name, a line about the strategy, a team page and a login. That is not lazy design. It is the result of two US rule sets, the private placement rules and the investment adviser Marketing Rule, which limit what a fund can say to the public. This guide explains both, so the design starts from what the site is allowed to do.

Can a hedge fund website be public?

Yes, but what it says in public depends on how the fund raises money. SEC staff guidance (Compliance and Disclosure Interpretation 256.23) says that using "an unrestricted, publicly available website" to offer securities is a general solicitation, which Rule 506(b) forbids. The same guidance (256.24 and 256.25) says information that does not involve an offer of securities, such as factual business information about the firm, may be spread widely.

So under 506(b), the public site describes the manager; the fund itself, its terms and its returns sit behind a password for people with whom you already have a relationship.

How does investor gating work under Rule 506(b)?

The gate has to do more than ask a question. SEC staff say a "pre-existing, substantive relationship" is one way, though not the only way, to show there was no general solicitation (256.26), that it must exist before the offering starts (256.29 and 256.30), and that "self-certification alone (by checking a box)" without other knowledge of the person's finances is not enough (256.31).

The 2015 Citizen VC no-action letter is the usual reference for doing this online: the platform built a relationship through questionnaires and contact before showing any offering behind a password, and commentators such as Mintz noted the staff focused on the quality of that relationship. Build the gate with your lawyer's process, not a tick box.

What changes under Rule 506(c)?

Rule 506(c) lets you "broadly solicit and generally advertise" the offering, so the fund can be marketed publicly, provided every purchaser is accredited and you take reasonable steps to verify it. In March 2025 SEC staff accepted high minimum investments ($200,000 for individuals, $1 million for most entities) plus written representations as one way to do that, according to King & Spalding. The website then needs a verification step before subscription, not before reading.

What does the SEC Marketing Rule say about performance?

The Marketing Rule (17 CFR 275.206(4)-1) is written for SEC-registered advisers and has applied since November 2022. For a fund website, these are the parts that matter most:

• No untrue or unsubstantiated statements, and potential benefits only with fair and balanced treatment of material risks (SEC, 2020).
• Gross performance only with net performance shown with at least equal prominence, over the same period and method.
• Standard 1-, 5- and 10-year periods are required for other portfolios but not for private funds, so a fund page is not bound by that table.
• Hypothetical performance (backtests, model portfolios, targets) only with policies to make it relevant to the audience and an explanation of assumptions and risks.
• Testimonials and endorsements only with clear disclosure of whether the person is a client and whether they are paid.

Which pages should be public and which gated?

This is a common split under Rule 506(b); confirm yours with counsel.

What should the investor area do?

The gated area is where the fund is actually presented, so it deserves as much design attention as the public site.

• Separate logins per investor or prospect, so access can be granted and withdrawn individually.
• Documents served from the administrator's or data-room portal where possible, with download logs.
• Factsheets and letters with the performance disclosures built into the template.
• Clear contact routes to investor relations, and no public links into gated pages.

What disclaimers does a fund website need?

Counsel will write the exact words. Expect these elements:

• Not an offer: the site is not an offer to sell or a solicitation to buy any security.
• Eligibility: fund information is only for qualifying investors in permitted jurisdictions.
• Past performance is not indicative of future results, near any performance figure.
• Registration status stated accurately, without implying SEC approval.
• Privacy and cookie notices for the gate and the contact form.

What else makes a fund website credible?

Allocators check the website before a meeting and again during due diligence. What helps: real names and backgrounds, a clear statement of service providers if counsel allows it, a working investor login, a fast and accessible site, and nothing that reads like retail marketing. For the wider checklist of regulated-site basics see financial services website design.

PipValley builds websites for prop firms and the trading businesses next to them. We have not built a hedge fund site for a client; we would build yours around your counsel's review, with the gate designed in from the start. See websites for hedge funds and trading firms.

Questions

Sources

1. SEC: Securities Act Rules compliance and disclosure interpretations (Section 256, Rule 502)
2. Mintz: Citizen VC no-action letter, conducting a private placement online (Aug 2015)
3. SEC: Private placements, Rule 506(b)
4. SEC: General solicitation, Rule 506(c)
5. King & Spalding: SEC staff no-action letter eases Rule 506(c) verification (Mar 2025)
6. Cornell LII: 17 CFR 275.206(4)-1, investment adviser marketing
7. SEC press release 2020-334: SEC adopts modernized marketing rule
8. SEC press release 2023-173: Marketing rule sweep, charges against nine advisers