In Their Words: Testimonials, Endorsements, and Promoters

About the course

For about sixty years, an investment adviser could not use a client's praise in an advertisement. The SEC's Marketing Rule changed that. An SEC-registered adviser may now use client testimonials, pay for endorsements and referrals, and advertise awards and rankings, if it meets specific conditions for disclosure, oversight, written agreements, and the disciplinary history of the people it pays. This beginner-level course explains those conditions in plain language and assumes no prior knowledge of the rule. It starts with the basics, then shows how everyday activities fall under the rule: online reviews, refer-a-friend programs, referral fees to accountants and attorneys, lead-generation websites, paid influencers, and networking-profile recommendations. It covers what must be disclosed and where, what a promoter agreement must contain, who may not be paid, and how the exemptions work. It also addresses third-party ratings, state-registered advisers after NASAA's May 2026 model rule amendments, Form ADV reporting, and recordkeeping. The final module turns to practice: the deficiencies SEC examiners reported in their December 2025 risk alert, a six-step review for any proposed arrangement, and three case studies. A glossary and a rule reference table are included. The course is written for the individual IAR, because most problems in this area begin with one person doing something that seems ordinary.