FINTECH & WEALTH MANAGEMENT MARKETING

RIA Compliance Marketing Guidelines For Fintech Wealth Management Firms

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Charles Menke
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RIA compliance marketing guidelines represent a comprehensive framework that governs how Registered Investment Advisors must conduct their marketing and advertising activities under SEC and state regulatory oversight. These rules, fundamentally reshaped by the SEC's Marketing Rule (Rule 206-4) that took effect in November 2022, establish strict standards for all promotional communications while enabling modern digital marketing approaches for wealth management firms. This article explores RIA compliance marketing guidelines within the broader context of fintech and wealth management marketing, providing institutional finance marketers with essential compliance frameworks for navigating today's regulatory landscape.

Key Summary: RIA compliance marketing requires adherence to the SEC Marketing Rule, prohibiting false or misleading statements while mandating specific disclosures for testimonials, performance data, and third-party ratings across all digital channels.

Key Takeaways:

  • The SEC Marketing Rule modernized RIA advertising regulations, replacing the previous advertising and cash solicitation rules
  • All marketing materials must avoid false, misleading, or deceptive content with rigorous substantiation requirements
  • Performance advertising requires specific disclosures, fair representation, and careful consideration of cherry-picking concerns
  • Testimonials and endorsements need detailed disclosures about compensation, conflicts, and material connections
  • Social media and digital marketing fall under the same compliance framework as traditional advertising
  • Books and records requirements mandate comprehensive documentation of all marketing materials and their approval processes
  • Third-party rating disclosures must explain methodology, criteria, and any compensation arrangements

What Is the SEC Marketing Rule for RIAs?

The SEC Marketing Rule (Rule 206-4 under the Investment Advisers Act) is the primary regulatory framework governing all advertising and promotional activities by Registered Investment Advisors. Effective November 4, 2022, this rule replaced the previous advertising rule (which hadn't been substantially updated since 1961) and the cash solicitation rule, creating a unified framework for modern marketing practices. The rule applies to all communications directed to more than one person that offer or promote advisory services, regardless of the medium used.

Marketing Rule: SEC Rule 206-4 that prohibits RIAs from making false or misleading statements in advertisements while establishing specific requirements for testimonials, performance data, and third-party ratings. SEC Final Rule

The Marketing Rule operates on a principles-based approach rather than prescriptive prohibitions, giving RIAs more flexibility while requiring greater responsibility for ensuring compliance. This shift acknowledges the digital transformation of marketing while maintaining investor protection standards. Under this framework, RIAs must evaluate each marketing communication against the general prohibition on false and misleading statements, plus specific requirements for certain content types.

Core Elements of the Marketing Rule:

  • General Prohibition: Bars false or misleading advertisements under any circumstances
  • Substantiation Requirement: RIAs must have reasonable basis for material statements before publication
  • Performance Advertising: Specific rules for presenting investment performance data
  • Testimonials and Endorsements: Requirements for disclosure when featuring client or third-party endorsements
  • Third-Party Ratings: Rules for advertising awards, rankings, or ratings from external organizations
  • Books and Records: Documentation requirements for all marketing materials and approval processes

How Does the General Prohibition Work?

The general prohibition serves as the foundational principle of RIA marketing compliance, stating that investment advisers cannot make any untrue statement of material fact or omit material facts that would make statements misleading. This broad prohibition requires RIAs to evaluate every marketing communication through multiple lenses: accuracy, completeness, context, and potential for investor confusion.

Under the general prohibition, materiality is determined from the perspective of a reasonable investor - would this information significantly alter an investment decision? This includes not just factual accuracy but also the overall impression created by marketing materials. For example, presenting only positive client outcomes without acknowledging that results vary would likely violate the general prohibition even if each individual statement is technically accurate.

Key Prohibition Areas:

  • False Statements: Any factually incorrect claims about services, performance, or firm characteristics
  • Misleading Implications: Content that creates false impressions even if individual statements are accurate
  • Material Omissions: Failing to include information that would significantly impact investor understanding
  • Unsubstantiated Claims: Making material statements without reasonable basis or supporting documentation
  • Cherry-Picking: Selectively presenting favorable information while omitting material negative information
  • Guaranteed Outcomes: Implying specific investment results or guaranteed returns

The SEC expects RIAs to implement robust review procedures to ensure compliance with the general prohibition. This includes establishing approval processes for marketing materials, training marketing personnel on compliance requirements, and maintaining documentation that demonstrates the reasonable basis for material claims. Investment advisers working with specialized agencies like WOLF Financial often benefit from external compliance review processes that help identify potential issues before publication.

What Are the Performance Advertising Requirements?

Performance advertising under the Marketing Rule allows RIAs to present investment returns with specific safeguards designed to prevent misleading presentations. RIAs can advertise gross performance, net performance, or related performance, but each type requires particular disclosures and fair representation standards. The rule eliminates previous restrictions on showing performance but imposes rigorous requirements to ensure presentations don't mislead prospective clients.

Net Performance: Investment returns calculated after deduction of all fees and expenses that would be charged to advisory clients, providing the most accurate representation of actual client experience. SEC Marketing Rule

When advertising performance, RIAs must consider whether the presentation provides fair and balanced information that would allow reasonable investors to evaluate the advisor's investment performance. This means avoiding cherry-picking favorable periods while ensuring that performance presentations include appropriate context about market conditions, risk factors, and the general variability of investment returns.

Performance Advertising Categories:

Gross Performance Requirements:

  • Must be accompanied by net performance for the same period
  • Requires disclosure that performance doesn't reflect deduction of fees
  • Must explain that fee deduction would reduce returns shown
  • Should include description of the advisor's fees

Net Performance Standards:

  • Calculated after deduction of actual advisory fees paid by clients
  • Must reflect fees and expenses that would actually be charged
  • Requires disclosure of what fees and expenses were deducted
  • Generally considered the most appropriate for advertising purposes

Related Performance Considerations:

  • Must be relevant to services being advertised
  • Requires disclosure of material differences between advertised and available services
  • Should include information about the similarity of investment strategies
  • Must address any material differences in market conditions or time periods

How Must RIAs Handle Testimonials and Endorsements?

The Marketing Rule permits RIAs to use client testimonials and third-party endorsements while requiring comprehensive disclosures about compensation, conflicts of interest, and the nature of the endorser's relationship with the advisor. This represents a significant change from previous rules that largely prohibited testimonials, reflecting recognition that client feedback can provide valuable information to prospective investors when properly disclosed.

RIAs must distinguish between testimonials (statements by current or former clients) and endorsements (statements by non-clients who promote the advisor's services). Each category has specific disclosure requirements designed to help prospective clients understand potential biases, compensation arrangements, and the context in which the statements were made.

Testimonial Disclosure Requirements:

  • Compensation Disclosure: Clear statement if the client received any compensation for the testimonial
  • Material Conflicts: Description of any conflicts of interest between the adviser and client
  • Atypical Results Warning: Statement that the testimonial may not be representative of other clients' experiences
  • No Guarantee Language: Disclosure that testimonials don't guarantee future performance or success
  • Selection Criteria: If testimonials were solicited, explanation of any selection criteria used

Endorsement Disclosure Requirements:

  • Material Connection: Clear disclosure of the relationship between endorser and adviser
  • Compensation Details: Description of any compensation, including cash and non-cash payments
  • Ongoing Arrangement: Whether the endorsement is part of an ongoing promotional arrangement
  • Endorser Qualifications: Relevant background information about the endorser's expertise
  • Terms and Conditions: Any material terms of the endorsement agreement

What Are Third-Party Rating Compliance Requirements?

Third-party ratings, including industry awards, rankings, and recognition from external organizations, can be powerful marketing tools for RIAs when properly disclosed and contextually presented. The Marketing Rule requires specific disclosures about rating methodologies, criteria, and any compensation arrangements while ensuring that ratings presentations don't create misleading impressions about the advisor's capabilities or performance.

RIAs must evaluate whether third-party ratings could mislead investors by suggesting qualities, characteristics, or credentials that the advisor doesn't possess. This includes considering whether the rating methodology aligns with services actually provided and whether the rating criteria would be material to prospective clients' investment decisions.

Required Third-Party Rating Disclosures:

  • Rating Organization: Identity and brief description of the organization providing the rating
  • Selection Criteria: Explanation of the factors and methodology used to determine the rating
  • Compensation Arrangements: Whether the adviser paid for the rating or related promotional opportunities
  • Time Period: The period covered by the rating and when it was awarded
  • Number of Advisors: How many advisers were evaluated for the rating, if known
  • Limitations: Any material limitations on the rating's scope or applicability
Comparison: Popular Industry Ratings

Barron's Top Financial Advisors:

  • Pros: Well-recognized brand, comprehensive evaluation criteria, no payment required
  • Cons: Limited to larger practices, focuses heavily on AUM metrics
  • Best For: Established advisors with significant assets under management

Forbes Best-In-State Wealth Advisors:

  • Pros: Geographic focus appeals to local clients, considers multiple practice factors
  • Cons: Methodology not fully transparent, potential confusion with paid Forbes content
  • Best For: Advisors seeking regional recognition and credibility

Financial Times 400 Top Advisors:

  • Pros: Prestigious publication, rigorous vetting process, international recognition
  • Cons: Very selective, focuses on ultra-high-net-worth practices
  • Best For: Elite advisors serving institutional or ultra-wealthy clients

How Does Social Media Marketing Comply with RIA Rules?

Social media marketing by RIAs falls under the same Marketing Rule framework as traditional advertising, meaning all posts, videos, podcasts, and digital content must comply with the general prohibition against false and misleading statements. The interactive and immediate nature of social media creates additional compliance challenges, particularly around unsolicited investment advice, client confidentiality, and the ability to provide adequate disclosures within platform constraints.

RIAs must implement social media policies that address content approval, disclosure requirements, and response procedures for public comments or questions. The challenge lies in maintaining compliance while leveraging social media's engagement benefits, particularly when dealing with character limits, video formats, or live streaming that don't easily accommodate lengthy regulatory disclosures.

Social Media Compliance Framework:

  • Content Approval: Establish review procedures for all social media content before publication
  • Disclosure Adaptation: Develop platform-appropriate methods for required disclosures
  • Interaction Guidelines: Set boundaries for responding to comments, questions, or direct messages
  • Recordkeeping: Maintain records of social media content and interactions as required
  • Platform Limitations: Address compliance challenges specific to each social media platform
  • Third-Party Content: Establish guidelines for sharing, retweeting, or commenting on external content

Specialized agencies managing compliance-aware social media campaigns, such as WOLF Financial with its vetted creator network, typically implement multi-layer review processes that ensure content meets regulatory requirements while maintaining engagement effectiveness across platforms ranging from LinkedIn to Twitter Spaces.

Platform-Specific Considerations:

LinkedIn Professional Content:

  • Best suited for educational content and thought leadership
  • Allows longer-form content that can accommodate fuller disclosures
  • Professional context reduces some compliance risks around unsuitable audiences
  • Article publishing feature enables comprehensive disclosure integration

Twitter/X Engagement:

  • Character limits challenge comprehensive disclosure presentation
  • Real-time interaction expectations conflict with content approval requirements
  • Thread functionality can help address disclosure space limitations
  • Hashtag usage must avoid creating misleading performance implications

Video and Podcast Content:

  • Verbal disclosures must be clear and prominently presented
  • Written disclosures in descriptions must be easily accessible
  • Live streaming creates challenges for real-time compliance monitoring
  • Guest appearances require consideration of endorsement disclosure requirements

What Books and Records Requirements Apply?

The Marketing Rule's books and records requirements mandate that RIAs maintain comprehensive documentation of all marketing materials, their approval processes, and supporting substantiation for material claims. These requirements extend beyond simply storing final marketing materials to include drafts, approval chains, performance calculations, and documentation demonstrating compliance with specific rule provisions.

Books and Records: Comprehensive documentation requirements under Rule 204-2 that RIAs must maintain for all marketing materials, including advertisements, performance calculations, testimonial agreements, and approval procedures for regulatory examination purposes.

RIAs must retain these records for five years from the date of last use, with the first two years requiring storage in appropriate offices where they're readily accessible for regulatory examination. The scope includes not just final published materials but also supporting documentation that demonstrates the reasonable basis for material statements and compliance with specific Marketing Rule provisions.

Required Marketing Records:

  • All Advertisements: Complete copies of all marketing materials in the form they were disseminated
  • Supporting Documentation: Materials substantiating factual claims and performance presentations
  • Approval Records: Documentation showing who reviewed and approved each marketing piece
  • Performance Calculations: Detailed records showing how advertised performance was calculated
  • Testimonial Agreements: Contracts and compensation arrangements with clients providing testimonials
  • Endorsement Documentation: Agreements and disclosures related to third-party endorsements
  • Distribution Lists: Records of where and to whom marketing materials were sent
  • Third-Party Rating Information: Documentation supporting third-party ratings and awards advertised

The books and records requirements serve multiple compliance functions: they enable regulatory examination of marketing practices, provide evidence of good-faith compliance efforts, and create accountability for marketing approval processes. RIAs should implement systematic record-keeping procedures that capture both the final marketing materials and the compliance analysis supporting their approval.

Which Pre-Use Review Requirements Must RIAs Follow?

While the Marketing Rule doesn't explicitly require pre-use review of marketing materials, most compliance experts recommend implementing formal approval procedures to ensure materials comply with the general prohibition and specific requirements before dissemination. The SEC has indicated that having reasonable procedures to prevent rule violations is a factor in enforcement consideration, making pre-use review a practical necessity for most RIAs.

Pre-use review procedures should be tailored to the RIA's size, complexity, and marketing activities while ensuring that all materials receive appropriate compliance analysis before publication. This includes evaluating content against the general prohibition, confirming required disclosures are present and adequate, and verifying that any performance data or testimonials meet rule requirements.

Effective Pre-Use Review Elements:

  • Written Procedures: Documented policies outlining review requirements and approval authority
  • Designated Reviewers: Specific individuals responsible for compliance review, with appropriate training
  • Review Checklist: Standardized evaluation criteria covering all Marketing Rule requirements
  • Documentation Requirements: Records showing review was conducted and any issues identified
  • Approval Authority: Clear designation of who has authority to approve different types of marketing materials
  • Revision Procedures: Process for handling materials that require modifications before approval

Many RIAs find that partnering with specialized compliance-focused marketing agencies provides additional review layers while maintaining marketing effectiveness. Agencies with deep regulatory expertise, such as those managing institutional finance campaigns, often provide compliance review as part of their standard service offering, helping identify potential issues before materials reach final approval stages.

How Do State Regulations Impact RIA Marketing?

State-registered investment advisers must comply with both SEC Marketing Rule principles and any additional state-specific requirements, creating a complex regulatory environment that varies by jurisdiction. While most states have adopted rules substantially similar to the federal Marketing Rule, some maintain additional restrictions or requirements that can impact marketing strategies, particularly around testimonials, performance advertising, or specific disclosure language.

RIAs operating in multiple states must ensure compliance with the most restrictive requirements across all jurisdictions where they conduct business or solicit clients. This jurisdictional complexity often requires careful legal analysis to identify applicable requirements and potential conflicts between federal and state rules.

Common State-Specific Variations:

  • Filing Requirements: Some states require pre-filing or notification of advertising materials
  • Additional Disclosures: State-specific language requirements for certain types of marketing content
  • Testimonial Restrictions: Some states maintain more restrictive approaches to client testimonials
  • Fee Disclosure: Enhanced requirements for fee presentation in marketing materials
  • Professional Designations: Rules governing use of professional credentials or designations
  • Social Media Guidance: State-specific interpretations of social media marketing requirements

RIAs should work with qualified legal counsel to identify applicable state requirements and ensure marketing procedures address both federal and state compliance obligations. This is particularly important for firms expanding into new states or those using digital marketing that may reach audiences across multiple jurisdictions.

What Enforcement Actions Should RIAs Know About?

The SEC has initiated enforcement actions related to Marketing Rule violations, providing important guidance about regulatory priorities and common compliance failures. These cases typically involve violations of the general prohibition through misleading statements, inadequate performance presentation, or failure to provide required testimonial disclosures, offering practical insights into regulatory expectations.

Enforcement cases demonstrate that the SEC focuses on materiality - whether marketing violations would significantly impact investor decision-making - rather than technical compliance failures. The cases also show that having reasonable compliance procedures, even if not perfect, can be a mitigating factor in enforcement consideration.

Common Enforcement Themes:

  • Performance Misrepresentation: Cherry-picking favorable periods or failing to provide adequate context
  • Misleading Credentials: Overstating qualifications, experience, or professional designations
  • Inadequate Disclosures: Failing to provide required testimonial or conflict-of-interest disclosures
  • False Statements: Material factual errors about services, performance, or firm characteristics
  • Unsubstantiated Claims: Making material statements without reasonable basis or supporting documentation
  • Social Media Violations: Applying different standards to social media content than traditional advertising

Recent enforcement actions suggest the SEC pays particular attention to digital marketing violations, including social media content that creates misleading impressions about advisor capabilities or performance. RIAs should view enforcement cases as educational resources that provide concrete examples of compliance failures to avoid.

Frequently Asked Questions

Basics

1. What is the difference between the old and new SEC Marketing Rule?

The new Marketing Rule, effective November 2022, replaced the 1961 advertising rule and cash solicitation rule with a unified, principles-based framework. Key changes include permitting testimonials with proper disclosures, allowing broader performance advertising, and modernizing rules for digital marketing while maintaining the core prohibition on false and misleading statements.

2. Who must comply with the SEC Marketing Rule?

All SEC-registered investment advisers must comply with the Marketing Rule. State-registered advisers follow similar rules adopted by their state regulators. The rule applies regardless of firm size, from solo practitioners to large institutional asset managers.

3. What constitutes "advertising" under the Marketing Rule?

Advertising includes any communication directed to more than one person that offers or promotes advisory services. This covers websites, social media, brochures, presentations, podcasts, videos, and any other promotional content, regardless of the medium used.

4. Can RIAs guarantee investment returns in their marketing?

No, RIAs cannot guarantee specific investment returns or outcomes. Such guarantees would violate the general prohibition against false and misleading statements, as investment performance cannot be guaranteed and involves inherent risks.

5. Are there different rules for different types of clients?

The Marketing Rule applies uniformly to all client communications, though RIAs must consider their target audience when evaluating whether content might be misleading. Materials directed to sophisticated institutional investors might appropriately include more complex information than retail client communications.

How-To

6. How should RIAs implement pre-use review procedures?

Establish written procedures designating specific individuals responsible for compliance review, create standardized checklists covering all Marketing Rule requirements, document the review process, and ensure reviewers receive appropriate training on current regulations and firm policies.

7. What's the best way to handle performance advertising compliance?

Use net performance when possible, ensure performance periods are representative, include appropriate disclosures about fees and market conditions, maintain detailed calculation records, and avoid cherry-picking favorable periods without proper context about overall performance patterns.

8. How can RIAs effectively use testimonials while staying compliant?

Provide all required disclosures about compensation and conflicts, include warnings that testimonials may not represent typical results, maintain records of testimonial agreements, and ensure testimonials accurately represent the client relationship and experience without creating misleading impressions.

9. What documentation should RIAs maintain for marketing materials?

Keep complete copies of all marketing materials, supporting documentation for factual claims, approval records, performance calculations, testimonial agreements, distribution records, and any correspondence related to marketing compliance for five years as required.

10. How should RIAs handle social media compliance?

Develop platform-specific compliance procedures, implement content approval processes, create guidelines for responding to comments, establish recordkeeping procedures for social media content, and ensure all required disclosures are appropriately presented within platform constraints.

Comparison

11. What's the difference between testimonials and endorsements?

Testimonials are statements by current or former clients about their experience with the adviser, while endorsements are promotional statements by non-clients. Both require specific disclosures, but endorsement disclosures focus more on the relationship between the endorser and adviser, including compensation arrangements.

12. Should RIAs use gross or net performance in advertising?

Net performance is generally preferred as it provides a more accurate representation of actual client experience. If using gross performance, RIAs must also show net performance for the same period and explain how fees would impact the returns shown.

13. How do federal and state RIA marketing rules compare?

Most state rules substantially mirror the federal Marketing Rule, but some states maintain additional requirements or restrictions. Multi-state RIAs must comply with the most restrictive requirements across all jurisdictions where they operate or solicit clients.

14. What's the difference between material and non-material marketing claims?

Material claims are those that would significantly influence an investor's decision-making and require greater substantiation and disclosure. Non-material claims, while still subject to accuracy requirements, typically need less extensive documentation and disclosure.

Troubleshooting

15. What should RIAs do if they discover a marketing compliance violation?

Immediately cease distribution of the problematic material, conduct an internal investigation to determine the scope of the violation, implement corrective measures, consider whether self-reporting to regulators is appropriate, and review procedures to prevent similar violations.

16. How can RIAs handle character limits on social media platforms?

Use abbreviation strategies for common disclosures, utilize platform features like threads or link-to-disclosure approaches, develop standardized shortened disclosure language that meets requirements, and consider whether the platform constraints make certain content types inappropriate for compliant presentation.

17. What if an RIA can't substantiate a marketing claim after publication?

Remove or modify the content immediately, document the issue and corrective action taken, review approval procedures to prevent similar problems, and consider whether additional remedial action or regulatory notification is required based on the materiality and scope of the unsubstantiated claim.

18. How should RIAs respond to negative comments on social media?

Follow established social media policies, avoid providing specific investment advice in public forums, protect client confidentiality, respond professionally if appropriate, and consider moving detailed discussions to private communications where proper disclosures and suitability analysis can be conducted.

Advanced

19. Can RIAs use artificial intelligence for marketing content creation?

Yes, but RIAs remain responsible for ensuring AI-generated content complies with all Marketing Rule requirements. This includes reviewing AI content for accuracy, providing required disclosures, maintaining substantiation for material claims, and ensuring the content doesn't create misleading impressions.

20. How do partnership marketing arrangements affect compliance?

Partnership marketing creates potential endorsement relationships that require disclosure of material connections and compensation arrangements. RIAs must ensure all parties understand compliance requirements and that joint marketing materials meet regulatory standards for all participants.

21. What special considerations apply to alternative investment marketing?

Alternative investments often require enhanced disclosures about liquidity, risk factors, and performance calculation methodologies. Marketing materials should clearly explain the unique characteristics and risks of alternative strategies while ensuring performance presentations don't mislead about typical results or risk levels.

Compliance/Risk

22. What are the penalties for Marketing Rule violations?

Violations can result in cease-and-desist orders, civil monetary penalties, disgorgement of profits, censure, suspension, or bar from the industry. Penalties depend on factors including violation severity, harm to investors, and the adviser's compliance history and cooperation.

23. How often should RIAs review their marketing compliance procedures?

Annual reviews are recommended at minimum, with additional reviews triggered by regulatory changes, business model changes, new marketing channels, enforcement actions affecting similar firms, or identified compliance issues. Regular training updates should accompany procedure reviews.

24. What insurance considerations relate to marketing compliance?

Professional liability insurance may cover certain marketing-related claims, but coverage varies significantly. RIAs should review their policies to understand coverage limitations, notification requirements, and exclusions related to regulatory violations or intentional misconduct in marketing activities.

25. How do marketing compliance failures affect custody and other regulatory requirements?

Marketing violations can trigger enhanced regulatory scrutiny of other compliance areas and may be considered in examinations for custody, fee calculations, fiduciary obligations, and overall compliance culture. Serious marketing violations could impact the adviser's ability to maintain registration or provide certain services.

Conclusion

RIA compliance marketing guidelines under the SEC Marketing Rule provide a comprehensive framework that enables modern marketing approaches while maintaining essential investor protections. The rule's principles-based approach requires RIAs to implement robust compliance procedures that ensure all marketing communications avoid false and misleading statements while meeting specific requirements for performance advertising, testimonials, and third-party ratings. Success in this regulatory environment depends on understanding both the letter and spirit of the regulations while building systematic compliance processes that can adapt to evolving marketing channels and techniques.

When developing compliant marketing strategies, consider these critical factors:

  • Implement comprehensive pre-use review procedures with documented approval processes
  • Establish robust recordkeeping systems that capture all required documentation for five-year retention periods
  • Develop platform-specific compliance approaches for social media and digital marketing channels
  • Create clear policies for handling testimonials, endorsements, and third-party ratings with appropriate disclosures
  • Maintain current knowledge of enforcement actions and regulatory guidance to refine compliance approaches

For institutional finance firms seeking to build compliant marketing strategies that effectively reach target audiences while navigating complex regulatory requirements, explore WOLF Financial's compliance-focused institutional marketing services that combine regulatory expertise with proven performance across creator networks and digital channels.

References

  1. Securities and Exchange Commission. "Marketing Rule for Investment Advisers." Final Rule Release No. IA-5653, December 22, 2020. https://www.sec.gov/rules/final/2020/ia-5653.pdf
  2. Securities and Exchange Commission. "Compliance Date for Marketing Rule for Investment Advisers." Release No. IA-5834, December 22, 2021. https://www.sec.gov/rules/final/2021/ia-5834.pdf
  3. Securities and Exchange Commission. "Books and Records Requirements for Investment Advisers." Rule 204-2 under the Investment Advisers Act. https://www.sec.gov/about/laws/iaa40.pdf
  4. Securities and Exchange Commission. "Fiduciary Interpretation Regarding Standard of Conduct for Investment Advisers." Release No. IA-5248, June 5, 2019. https://www.sec.gov/rules/interp/2019/ia-5248.pdf
  5. Financial Industry Regulatory Authority. "Social Media and Digital Communications." Regulatory Notice 17-18, April 2017. https://www.finra.org/rules-guidance/notices/17-18
  6. Securities and Exchange Commission. "Investment Adviser Marketing Rule: Frequently Asked Questions." Staff Guidance, Updated March 2023. https://www.sec.gov/investment/marketing-faq
  7. North American Securities Administrators Association. "Model Rule on the Use of Senior-Specific Certifications and Professional Designations." Adopted September 2008, Updated 2019. https://www.nasaa.org/policy/model-rules-guidelines/
  8. Securities and Exchange Commission. "Risk Alert: Observations from Investment Adviser Marketing Rule Examinations." Office of Compliance Inspections and Examinations, September 2023. https://www.sec.gov/files/exams-marketing-rule-risk-alert.pdf
  9. Investment Adviser Association. "Marketing Rule Implementation Guide." Industry Best Practices, Updated 2023. https://www.investmentadviser.org/resources/marketing-rule
  10. Securities and Exchange Commission. "Form ADV Part 2A: Firm Brochure and Part 2B: Brochure Supplement." Instructions and General Information. https://www.sec.gov/about/forms/formadv-instructions.pdf

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: 2024 · Last updated: 2024-11-03T00:00:00Z

About the Author

Author: Gav Blaxberg, Founder, WOLF Financial
LinkedIn Profile

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