Testimonial disclosure requirements in finance represent one of the most critical compliance areas for financial institutions engaging in marketing activities. These regulations, primarily governed by SEC advertising rules and FINRA Rule 2210, mandate specific disclosures when financial firms use client testimonials, endorsements, or third-party recommendations in their marketing materials. This article explores testimonial disclosure requirements finance within the broader context of Compliance-First Marketing for Financial Institutions, providing institutional marketers with the regulatory framework needed for compliant testimonial campaigns.
Key Summary: Financial institutions must include specific disclosures when using testimonials, including compensation details, material connections, risk warnings, and performance disclaimers to comply with SEC and FINRA regulations.
Key Takeaways:
- SEC Rule 206(4)-1 requires detailed disclosures for investment adviser testimonials, including compensation and material connections
- FINRA Rule 2210 governs broker-dealer communications and mandates specific risk disclosures for testimonial content
- All testimonials must include clear statements about compensation, relationships, and the atypical nature of featured results
- Performance-based testimonials require additional disclaimers about past performance and individual results
- Social media testimonials are subject to the same disclosure requirements as traditional advertising materials
- Compliance violations can result in significant regulatory penalties and reputational damage
- Regular auditing and approval processes are essential for maintaining testimonial compliance standards
What Are Testimonial Disclosure Requirements in Finance?
Testimonial disclosure requirements in finance are regulatory mandates that financial institutions must follow when using client testimonials, endorsements, or third-party recommendations in their marketing materials. These requirements ensure transparency about compensation, relationships, and the representativeness of featured experiences.
The regulatory framework stems from multiple sources, including SEC Rule 206(4)-1 for investment advisers, FINRA Rule 2210 for broker-dealers, and FTC guidelines for general advertising. Financial institutions must navigate this complex regulatory landscape to avoid violations that can result in substantial penalties and enforcement actions.
Investment Adviser Testimonial: Any statement by a current or former client about their experience with an investment adviser, including comments about the adviser's services, performance, or professional qualities. Learn more from the SEC
The scope of testimonial disclosure requirements extends beyond traditional advertising to include social media posts, video content, podcast appearances, and digital marketing campaigns. This comprehensive coverage ensures that investors receive consistent information regardless of the marketing channel used.
Key regulatory areas include:
- Compensation disclosure requirements for paid testimonials
- Material relationship disclosures between institutions and endorsers
- Performance disclaimers for results-based testimonials
- Risk warnings appropriate to the investment products or services
- Approval and oversight procedures for testimonial content
How Does SEC Rule 206(4)-1 Govern Investment Adviser Testimonials?
SEC Rule 206(4)-1, effective November 2021, modernized the regulatory framework for investment adviser testimonials and endorsements. The rule replaced the previous prohibition-based approach with a principles-based framework that allows testimonials with appropriate disclosures and oversight.
Under this rule, investment advisers can use testimonials provided they implement comprehensive disclosure and oversight procedures. The regulation distinguishes between testimonials (client statements about their experience) and endorsements (third-party promotional statements), with specific requirements for each category.
Core SEC disclosure requirements include:
- Clear disclosure of all compensation paid to testimonial providers
- Description of material conflicts of interest between the adviser and endorser
- Statement that past performance does not guarantee future results
- Explanation of material terms and conditions of any compensation arrangements
- Risk disclosures appropriate to the services being promoted
- Contact information for obtaining additional information about the testimonial
The rule also requires investment advisers to maintain written policies and procedures reasonably designed to prevent violations. These procedures must address testimonial approval processes, disclosure verification, and ongoing monitoring of compliance requirements.
Agencies specializing in financial services marketing, such as WOLF Financial, build compliance review into every campaign to ensure adherence to SEC Rule 206(4)-1 requirements while maintaining effective marketing messaging.
What Constitutes Adequate Compensation Disclosure?
Adequate compensation disclosure under SEC rules requires clear, prominent statements about all forms of payment or benefits provided to testimonial providers. This includes cash payments, fee reductions, gifts, services, or any other form of consideration.
The disclosure must be specific enough for investors to understand the nature and scope of the compensation arrangement. Generic statements like "compensated endorser" are generally insufficient; disclosures should specify the type and approximate amount of compensation when material to the testimonial's credibility.
Why Are FINRA Rule 2210 Requirements Critical for Broker-Dealers?
FINRA Rule 2210 governs communications with the public by broker-dealers, including testimonial and endorsement content. This rule requires that all communications be based on principles of fair dealing, good faith, and provide a sound basis for evaluating the facts presented.
For testimonials specifically, FINRA Rule 2210 requires broker-dealers to ensure that featured client experiences are not misleading and include appropriate risk disclosures. The rule applies to all forms of communication, including social media, websites, videos, and traditional advertising materials.
FINRA Communications Standard: All member communications must be based on principles of fair dealing and good faith, provide a sound basis for evaluating facts, and not omit material facts that would make statements misleading. View FINRA Rule 2210
FINRA testimonial requirements include:
- Prominent disclosure of all compensation paid to testimonial providers
- Clear statements about the atypical nature of favorable results
- Risk warnings appropriate to the products or services featured
- Balanced presentation that doesn't overemphasize positive outcomes
- Proper approval and filing procedures for testimonial content
- Recordkeeping requirements for testimonial documentation
FINRA also requires that testimonials reflect typical client experiences or include disclaimers explaining how the featured experience may differ from what other clients might expect. This prevents the use of exceptionally positive results without proper context.
How Do Filing Requirements Apply to Testimonial Content?
FINRA Rule 2210 categorizes communications as institutional, retail, or correspondence, with different filing and approval requirements for each category. Testimonials in retail communications typically require pre-use approval by a registered principal and may need filing with FINRA.
Broker-dealers must maintain comprehensive records of testimonial content, including approval documentation, compensation agreements, and compliance reviews. These records must be readily available for regulatory examination and retained according to FINRA recordkeeping requirements.
What Specific Disclosures Must Financial Institutions Include?
Financial institutions must include multiple layers of disclosure when using testimonials, with specific requirements varying based on the type of institution, services promoted, and regulatory framework applicable. The disclosures must be clear, prominent, and easily understood by the target audience.
Effective disclosure strategies balance regulatory compliance with marketing effectiveness, ensuring that required information is communicated without overwhelming the testimonial's persuasive impact. This requires careful attention to disclosure placement, language, and formatting.
Comparison: Essential Disclosure Categories
Compensation Disclosures
- Requirements: Specific details about payment, benefits, or consideration provided
- Placement: Prominently displayed near testimonial content
- Language: Clear, specific terms avoiding generic phrases
- Examples: "Client received $500 for this testimonial" or "Client's advisory fees were reduced"
Relationship Disclosures
- Requirements: Description of material connections between institution and endorser
- Placement: Visible to audience before or during testimonial presentation
- Language: Straightforward explanation of relationship nature
- Examples: "Employee testimonial" or "Family member of firm principal"
Performance Disclaimers
- Requirements: Statements about past performance and individual results variation
- Placement: Prominently displayed with performance-related testimonials
- Language: Standard regulatory disclaimer language
- Examples: "Past performance does not guarantee future results" and "Individual results may vary"
Risk Warnings
- Requirements: Appropriate risk disclosures for featured products or services
- Placement: Visible and accessible to testimonial audience
- Language: Product-specific risk language
- Examples: "All investments carry risk of loss" or "Insurance products are not FDIC insured"
How Should Disclosures Be Formatted for Maximum Compliance?
Disclosure formatting significantly impacts regulatory compliance, with regulators emphasizing that disclosures must be clear and prominent rather than buried in fine print. The formatting should ensure that average consumers can easily locate and understand the required information.
Best practices include using contrasting colors, readable font sizes, strategic placement near testimonial content, and plain English language. Digital testimonials should ensure disclosures remain visible across different devices and screen sizes.
Which Social Media Platforms Require Special Testimonial Considerations?
Social media testimonials present unique compliance challenges due to platform-specific formatting constraints, character limitations, and the informal nature of social media communication. Financial institutions must ensure full regulatory compliance despite these technical limitations.
Each major platform requires adapted disclosure strategies that work within the platform's native features while meeting regulatory requirements. The informal nature of social media does not exempt financial institutions from testimonial disclosure obligations.
Platform-specific considerations:
- Twitter/X: Character limitations require concise disclosure language, often using hashtags like #ad or #sponsored, with links to full disclosures
- LinkedIn: Professional context allows more detailed disclosures within post content or comment sections
- Instagram: Visual-heavy platform requires creative disclosure integration using captions, story highlights, or overlay text
- YouTube: Video testimonials must include both verbal and written disclosures, typically in video description and on-screen text
- TikTok: Short-form video format requires integrated visual disclosures and comprehensive description text
- Facebook: Longer-form content allows detailed disclosures within post text or linked documentation
Institutional brands often partner with specialized agencies like WOLF Financial that maintain vetted creator networks and provide compliance oversight for social media testimonial campaigns across multiple platforms.
What Are the Risks of Insufficient Social Media Disclosures?
Insufficient social media disclosures can result in regulatory enforcement actions, with penalties similar to those for traditional advertising violations. Regulators increasingly scrutinize social media content and have brought enforcement actions against firms with inadequate disclosure practices.
The viral nature of social media content can amplify compliance violations, potentially exposing institutions to broader regulatory scrutiny and reputational damage. Clear policies and approval processes are essential for managing these risks effectively.
How Do Performance-Based Testimonials Require Additional Compliance Measures?
Performance-based testimonials that reference investment returns, account growth, or financial outcomes require enhanced disclosure and compliance measures beyond standard testimonial requirements. These testimonials present higher regulatory risk due to their potential to mislead investors about expected results.
Regulators pay particular attention to performance testimonials because they can create unrealistic expectations and influence investment decisions based on non-representative results. Compliance frameworks must address both disclosure requirements and substantiation standards for performance claims.
Performance Testimonial: Any client statement that references specific investment returns, account values, financial outcomes, or measurable results achieved through an institution's services. SEC investor guidance
Enhanced requirements for performance testimonials include:
- Detailed disclaimers about past performance and future results
- Context about market conditions during the performance period
- Information about the representativeness of the featured results
- Risk disclosures specific to the investment strategies or products
- Documentation supporting the performance claims made
- Clear statements about factors that contributed to the results
Financial institutions must maintain robust documentation for performance-based testimonials, including account statements, performance calculations, and verification of the testimonial's accuracy. This documentation must be readily available for regulatory examination.
What Documentation Standards Apply to Performance Claims?
Performance testimonials require comprehensive documentation standards that verify the accuracy of claims and provide context for regulatory review. Documentation must include original account statements, performance calculation methodologies, and timeline verification.
The documentation should demonstrate that performance claims are accurate, verifiable, and presented with appropriate context about market conditions, time periods, and risk factors that contributed to the results.
Why Are Approval Processes Essential for Testimonial Compliance?
Approval processes serve as the primary control mechanism for ensuring testimonial compliance, providing systematic review and documentation of regulatory requirements before content publication. These processes must be tailored to the institution's regulatory framework and marketing activities.
Effective approval processes balance thorough compliance review with operational efficiency, allowing marketing teams to execute campaigns while maintaining regulatory standards. The processes must address both initial approval and ongoing monitoring of testimonial content.
Core approval process elements include:
- Designated approval authority with appropriate regulatory knowledge
- Standardized review checklists covering all disclosure requirements
- Documentation procedures for approval decisions and modifications
- Timeline requirements for review and approval completion
- Escalation procedures for complex or questionable testimonials
- Regular process review and updates for regulatory changes
Larger institutions may implement multi-tier approval processes with different requirements based on testimonial type, distribution channel, and target audience. These processes must be documented in written policies and procedures as required by regulatory frameworks.
According to agencies managing 10+ billion monthly impressions across financial creator networks, the most effective campaigns prioritize education over promotion while maintaining rigorous approval standards for all testimonial content.
How Can Technology Streamline Testimonial Approval Workflows?
Technology solutions can significantly improve testimonial approval efficiency while maintaining compliance standards through automated workflows, standardized review processes, and comprehensive documentation systems.
Digital approval platforms can track review timelines, maintain approval documentation, and provide audit trails for regulatory examination while reducing manual processing time and improving consistency in compliance decisions.
What Recordkeeping Requirements Apply to Testimonial Campaigns?
Recordkeeping requirements for testimonial campaigns are comprehensive and must address both the testimonial content itself and all supporting documentation related to compliance review, approval, and monitoring. These records must be maintained for regulatory examination and potential enforcement proceedings.
Financial institutions must develop systematic recordkeeping procedures that capture all elements of testimonial campaigns, from initial client consent through final compliance review and ongoing monitoring activities.
Essential recordkeeping categories include:
- Original testimonial content and all versions or modifications
- Client consent and authorization documentation
- Compensation agreements and payment records
- Compliance review and approval documentation
- Distribution records showing where and when testimonials were used
- Performance substantiation for results-based testimonials
- Ongoing monitoring and review documentation
- Client communication records related to testimonial participation
Record retention periods typically align with general advertising recordkeeping requirements, often ranging from three to five years depending on the regulatory framework and institution type. Records must be readily accessible for regulatory examination and organized for efficient retrieval.
What Are the Consequences of Inadequate Recordkeeping?
Inadequate recordkeeping can result in regulatory penalties even when underlying testimonial practices are compliant, as regulators require institutions to demonstrate compliance through comprehensive documentation. Missing or incomplete records can trigger expanded regulatory examination and enforcement proceedings.
The inability to produce required records during examinations often results in regulatory findings and may indicate broader compliance deficiencies that trigger additional scrutiny of marketing practices.
How Should Financial Institutions Handle Testimonial Violations and Remediation?
Testimonial violations require immediate remediation actions to minimize regulatory exposure and prevent ongoing compliance issues. Effective violation response combines immediate corrective action with systematic process improvements to prevent recurrence.
Financial institutions should develop standardized violation response procedures that address discovery, assessment, corrective action, and process improvement phases of remediation efforts.
Violation response framework:
- Immediate Action: Suspend non-compliant testimonials and assess scope of violations
- Assessment: Evaluate regulatory exposure and determine necessary disclosures or corrections
- Remediation: Implement corrective actions including revised disclosures or content removal
- Communication: Notify relevant stakeholders and consider regulatory self-reporting
- Process Improvement: Revise policies and procedures to prevent similar violations
- Monitoring: Implement enhanced oversight for related testimonial activities
Self-reporting violations to regulators may demonstrate good faith compliance efforts and could influence regulatory response, though institutions should consult with legal counsel before making self-reporting decisions.
When evaluating potential partners, financial institutions should prioritize agencies with demonstrated regulatory expertise, established creator relationships, and transparent performance metrics to minimize violation risk.
What Role Does Legal Counsel Play in Violation Response?
Legal counsel plays a critical role in violation assessment, regulatory communication, and remediation strategy development, particularly for significant violations that may trigger enforcement proceedings or require regulatory notification.
Early legal involvement can help institutions navigate complex regulatory requirements, assess privilege protections for internal investigations, and develop appropriate communication strategies with regulators.
Which Industries Face Enhanced Testimonial Compliance Requirements?
Certain financial services sectors face enhanced testimonial compliance requirements due to the nature of their products, customer base, or regulatory oversight. These enhanced requirements reflect increased regulatory concern about consumer protection and market integrity.
Understanding sector-specific requirements is essential for developing appropriate compliance frameworks and avoiding industry-specific enforcement priorities that may result in heightened regulatory scrutiny.
Comparison: Sector-Specific Requirements
Investment Advisers
- Enhanced Requirements: SEC Rule 206(4)-1 compliance, detailed compensation disclosure, material conflict identification
- Key Focus Areas: Performance testimonials, fee arrangements, investment strategy endorsements
- Best Practices: Written policies, regular training, systematic approval processes
Broker-Dealers
- Enhanced Requirements: FINRA Rule 2210 compliance, fair dealing standards, balanced presentation requirements
- Key Focus Areas: Product suitability, risk disclosures, investment outcome representations
- Best Practices: Principal approval, filing procedures, ongoing supervision
Insurance Companies
- Enhanced Requirements: State insurance regulations, product-specific disclosures, claims substantiation
- Key Focus Areas: Policy benefits, claims experience, agent licensing disclosures
- Best Practices: Multi-state compliance, actuarial review, regulatory filing coordination
Banking Institutions
- Enhanced Requirements: FDIC advertising rules, truth-in-lending compliance, fair lending considerations
- Key Focus Areas: Deposit insurance coverage, loan terms, service availability
- Best Practices: Standardized disclosures, consistent messaging, comprehensive review processes
Frequently Asked Questions
Basics
1. What makes a statement a "testimonial" under financial regulations?
A testimonial is any statement by a current or former client about their experience with a financial institution's services, performance, or professional qualities. This includes written reviews, video statements, social media posts, and verbal endorsements used in marketing materials. The statement must relate to the client's actual experience rather than general commentary about financial markets.
2. Do all testimonials require compensation disclosure?
Yes, financial institutions must disclose all forms of compensation provided to testimonial participants, including cash payments, fee reductions, gifts, services, or any other benefits. Even non-monetary compensation like meals, event tickets, or promotional items must be disclosed if material to the testimonial's credibility.
3. What's the difference between testimonials and endorsements?
Testimonials are statements by actual clients about their personal experience with an institution's services. Endorsements are promotional statements by third parties who may not be clients, such as industry experts, celebrities, or influencers. Both require disclosures, but endorsements may have additional requirements for expert qualification disclosures.
4. Are social media testimonials subject to the same rules as traditional advertising?
Yes, social media testimonials must comply with the same disclosure requirements as traditional advertising materials. Platform limitations don't exempt institutions from compliance obligations, though they may affect disclosure formatting and placement strategies.
5. How long must institutions retain testimonial records?
Record retention requirements typically range from three to five years depending on the regulatory framework and institution type. SEC-registered investment advisers must retain testimonial records for five years, while FINRA member firms generally maintain records for three years with some exceptions for longer periods.
How-To
6. How should compensation disclosure be worded?
Compensation disclosure should be specific and clear, avoiding generic phrases like "compensated endorser." Effective disclosures specify the type and approximate amount when material, such as "Client received $500 for this testimonial" or "Client's advisory fees were reduced by 50% for participation."
7. What approval process should institutions implement?
Effective approval processes include designated approval authority with regulatory knowledge, standardized review checklists covering all disclosure requirements, documentation procedures for decisions, timeline requirements for completion, and escalation procedures for complex testimonials. Written policies should define roles, responsibilities, and review criteria.
8. How can institutions verify testimonial accuracy?
Institutions should obtain written consent from clients, verify the accuracy of statements made, maintain supporting documentation for performance claims, and document the client relationship and experience timeframe. Performance-based testimonials require additional substantiation through account statements and calculation verification.
9. What steps should institutions take when discovering violations?
Upon discovering violations, institutions should immediately suspend non-compliant testimonials, assess the scope of violations, implement corrective actions including revised disclosures, notify relevant stakeholders, consider regulatory self-reporting, revise policies to prevent recurrence, and implement enhanced monitoring for related activities.
10. How should institutions handle client requests to modify testimonials?
Client modification requests should be evaluated for compliance impact, documented thoroughly, and re-approved through the institution's standard review process. Material changes may require new disclosure reviews and approval documentation.
Comparison
11. What's the difference between SEC and FINRA testimonial requirements?
SEC Rule 206(4)-1 applies to investment advisers and focuses on compensation disclosure and conflict identification. FINRA Rule 2210 applies to broker-dealers and emphasizes fair dealing standards, balanced presentation, and risk disclosure. Both require comprehensive documentation but have different filing and approval procedures.
12. How do state regulations interact with federal testimonial requirements?
State regulations may impose additional requirements beyond federal standards, particularly for insurance products and state-registered investment advisers. Institutions must comply with both federal and applicable state requirements, often requiring coordination across multiple regulatory frameworks.
13. What are the key differences between testimonial requirements for different financial products?
Investment product testimonials require detailed performance disclaimers and risk warnings. Insurance testimonials need product-specific disclosures about coverage limitations. Banking testimonials must address FDIC insurance coverage and service availability. Each product type has specific regulatory focus areas and disclosure requirements.
14. How do testimonial requirements differ between retail and institutional clients?
Retail client testimonials typically require more detailed disclosures and enhanced consumer protection measures. Institutional client testimonials may have different disclosure standards but still require compensation and relationship disclosures. The sophistication of the target audience affects disclosure language and presentation requirements.
Troubleshooting
15. What if a client withdraws consent for testimonial use?
Institutions must immediately cease using testimonials when client consent is withdrawn, remove content from all marketing channels, document the withdrawal, and update records to reflect the change. Ongoing monitoring should ensure complete removal from all distribution channels.
16. How should institutions handle negative testimonials or reviews?
Institutions should not selectively edit or suppress negative testimonials in a misleading way. If using testimonials in marketing, the presentation should be balanced and not misleading. Institutions can choose which testimonials to feature but cannot materially alter content to change its meaning.
17. What if testimonial content becomes non-compliant due to regulatory changes?
Institutions should regularly review existing testimonial content for ongoing compliance, update disclosures as needed for regulatory changes, maintain documentation of compliance reviews, and establish sunset dates for testimonial content to trigger periodic review.
18. How should institutions address testimonials that mention competitors?
Comparative testimonials require additional scrutiny to ensure fair and accurate comparisons, proper substantiation for claims made, and appropriate disclosures about the basis for comparisons. Institutions should verify the accuracy of competitive information and avoid misleading comparisons.
Advanced
19. Can institutions use testimonials from employees or family members?
Employee and family member testimonials are permitted but require prominent disclosure of the relationship. These testimonials may receive enhanced regulatory scrutiny due to potential bias, and institutions should consider whether they provide meaningful information to prospective clients.
20. How do testimonial requirements apply to third-party marketing platforms?
Financial institutions remain responsible for testimonial compliance even when using third-party platforms or aggregator sites. Institutions should ensure platform capabilities support required disclosures and maintain documentation of compliance efforts across all marketing channels.
21. What are the implications of using AI-generated or synthetic testimonials?
AI-generated testimonials would likely be considered misleading and violate regulatory requirements for authentic client experiences. Institutions should avoid synthetic testimonials and ensure all featured statements represent genuine client experiences with appropriate disclosures.
Compliance/Risk
22. What penalties can institutions face for testimonial violations?
Penalties for testimonial violations can include regulatory censure, monetary fines, corrective action requirements, enhanced supervision, and reputational damage. Recent enforcement actions have resulted in fines ranging from tens of thousands to millions of dollars depending on violation severity and scope.
23. How do testimonial violations affect regulatory examination outcomes?
Testimonial violations can trigger expanded examination scope, additional regulatory scrutiny of marketing practices, enhanced ongoing supervision requirements, and potential referral for enforcement action. Violations may also indicate broader compliance deficiencies requiring systematic remediation.
24. What role does recordkeeping play in testimonial compliance defense?
Comprehensive recordkeeping is essential for demonstrating compliance efforts, supporting regulatory examination responses, and mitigating enforcement exposure. Institutions with thorough documentation typically receive more favorable regulatory treatment and can more effectively defend against violation allegations.
25. How should institutions address testimonial compliance in crisis situations?
Crisis situations require immediate assessment of testimonial content for ongoing appropriateness, potential suspension of campaigns during volatile periods, enhanced monitoring of client sentiment, and clear communication procedures for addressing testimonial-related concerns during reputational challenges.
Conclusion
Testimonial disclosure requirements in finance represent a critical compliance area that requires systematic attention to regulatory frameworks, comprehensive documentation procedures, and ongoing monitoring processes. Financial institutions must navigate complex requirements from multiple regulators while maintaining effective marketing communications that build client trust and business growth.
When developing testimonial compliance frameworks, institutions should prioritize clear disclosure strategies, robust approval processes, and comprehensive recordkeeping systems that demonstrate regulatory adherence. The investment in compliance infrastructure pays dividends through reduced regulatory risk, enhanced client trust, and sustainable marketing practices that support long-term business objectives.
For financial institutions seeking to develop compliant testimonial marketing strategies while navigating complex regulatory requirements, explore WOLF Financial's compliance-forward marketing services that combine regulatory expertise with proven institutional marketing strategies.
References
- Securities and Exchange Commission. "Investment Adviser Marketing Rule." Final Rule Release No. IA-5653, December 2020. https://www.sec.gov/rules/final/2020/ia-5653.pdf
- Financial Industry Regulatory Authority. "FINRA Rule 2210: Communications with the Public." FINRA Rulebook. https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210
- Securities and Exchange Commission. "Investor Alerts: Testimonials." Office of Investor Education and Advocacy. https://www.sec.gov/investor/alerts/testimonials.pdf
- Federal Trade Commission. "FTC's Endorsement Guides: What People Are Asking." Division of Advertising Practices, September 2017. https://www.ftc.gov/tips-advice/business-center/guidance/ftcs-endorsement-guides-what-people-are-asking
- FINRA. "Regulatory Notice 17-18: Social Media and Digital Communications." May 2017. https://www.finra.org/rules-guidance/notices/17-18
- Securities and Exchange Commission. "IM Guidance Update: Investment Adviser Marketing Rule." Division of Investment Management, May 2021. https://www.sec.gov/investment/im-guidance-2021-02.pdf
- FINRA. "Report on Examination Findings and Observations." Risk Monitoring and Examination Program, 2023. https://www.finra.org/rules-guidance/guidance/reports/2023-report-exam-findings-and-observations
- Securities and Exchange Commission. "Risk Alert: Investment Adviser Marketing Rule Compliance." Office of Compliance Inspections and Examinations, March 2022. https://www.sec.gov/files/investment-adviser-marketing-rule-risk-alert.pdf
- Congressional Research Service. "Financial Services Advertising Regulation Overview." R46789, Updated January 2023. https://crsreports.congress.gov/product/pdf/R/R46789
- American Bar Association. "Investment Adviser Regulation: Testimonials and Endorsements." Business Law Section, 2022. https://www.americanbar.org/groups/business_law/publications/blt/2022/03/testimonials/
- FINRA. "Advertising Regulation Department: Frequently Asked Questions." https://www.finra.org/rules-guidance/key-topics/advertising-regulation/advertising-faq
- North American Securities Administrators Association. "Model Rule on Investment Adviser Marketing." Adopted April 2022. https://www.nasaa.org/policy/model-rules-and-legislation/
Important Disclaimers
Disclaimer: Educational information only. Not financial, legal, medical, or tax advice.
Risk Warnings: All investments carry risk, including loss of principal. Past performance is not indicative of future results.
Conflicts of Interest: This article may contain affiliate links; see our disclosures.
Publication Information: Published: 2025-01-27 · Last updated: 2025-01-27T00:00:00Z
About the Author
Author: Gav Blaxberg, Founder, WOLF Financial
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