Despite going into effect almost a year and a half ago, many questions still persist within the private funds industry about the best way to comply with the new Marketing Rule. In lieu of the comprehensive guidance the industry has long sought from the SEC, the Commission updated its FAQ on February 6, 2024, to clarify the SEC Division of Investment Management’s expectations as to the time periods and methodologies fund managers must use when calculating gross and net performance metrics to ensure they properly reflect the impact of subscription credit facilities. Although the FAQ purports to provide detailed guidance on the discrete issues addressed therein, open questions remain such as how to logistically prepare the calculations mandated in the FAQ, how much disclosure will be considered adequate to satisfy the requirement and what measures, if any, fund managers need to take as to their non-compliant existing marketing materials. This article summarizes the FAQ and provides insights from industry experts regarding the key takeaways for private fund advisers. For coverage of the FAQ update released in January 2023, see our two-part series: “How to Present Individual Positions and Deal With Attribution Issues” (Apr. 6, 2023); and “Practical Implications and Special Q&A With CCOs” (Apr. 20, 2023).