A fund wholesaler agreed to pay a $300,000 fine to settle FINRA charges that marketing material used with other broker-dealers and institutional investors were misleading.  FINRA charges that the marketing materials (which were prepared by a third party affiliate) were not fair and balanced because the materials (i) failed to disclose that the fund did not qualify as a REIT for tax purposes, (ii) made incorrect claims about the fund’s diversification, (iii) made generalized and unsupported claims about the benefits, predictability, and consistency of investing in the targeted assets, (iv) referenced past investments by institutional investors in similar assets, and (v) utilized a comparison index that was not truly representative.  FINRA cited violations of Rule 2210 because the marketing materials did not have fair and balanced disclosure.