What’s changed — and why it matters
- Effective November 4, 2022, the SEC’s refreshed “Marketing Rule” (Rule 206(4)-1 under the Investment Advisers Act) officially allows SEC-registered investment advisers to solicit and use client reviews, testimonials, endorsements, and third-party ratings in marketing materials (comply.com).
- In practical terms, this means advisers can ask clients to provide honest reviews, publish them on their website or Google Business profiles, and even feature them in emails, ads, and social media—so long as they follow all prescribed compliance steps .
- Testimonials are statements from current clients, while endorsements come from non-clients or past clients. Both are now permitted, with the usual focus on ensuring full transparency (kitces.com).
Key compliance safeguards
- No cherry‑picking
You must invite all clients, not just your best, to provide reviews (secmarketingrule.com). - Avoid entanglement
You cannot edit, remove, or steer client reviews to make them more favorable—doing so transforms them into marketing materials subject to full scrutiny. - Proper disclosures
If a reviewer is paid more than $1,000 or receives non-cash compensation, that must be clearly disclosed; written agreements are required (secmarketingrule.com). - Recordkeeping & policies
Firms must maintain written policies and procedures, archive review collection and publication communications for five years, and document that their review process is SEC-compliant (secmarketingrule.com).
Hello, referrals—goodbye, guesswork!
- Reviews act like “evergreen referrals”, helping build trust long-term by sharing real client experiences (kitces.com).
- Stats show that consumers trust online reviews as much as personal recommendations. For financial advisors, this offers a powerful opportunity—if done the right way (kitces.com).
- Firms that have embraced this change (e.g., by adding testimonial pages or using quotes in slideshows, emails, social posts) are seeing engagement benefits (barrons.com).
Why partner with a compliant platform provider
Navigating the SEC’s new rule isn’t just about asking clients nicely—it requires a robust, auditable system. That’s where compliant review-platform partners come in:
- Automated compliance workflows ensure invitations go to all clients, monitor for entanglement, integrate required disclosures, and archive everything for SEC audits.
- Built-in safeguards against editing or filtering reviews, so you can publish content confidently and defend compliance under scrutiny.
- Better workflows = more reviews: platforms often provide prompts and follow-ups that encourage clients to respond—without compromising compliance.
- Peace of mind during SEC exams: the rule is still relatively new, and enforcement (including fines) is ongoing for misleading ads or broken processes (comply.com).
Final take
The SEC’s updated Marketing Rule presents a rare opportunity for financial advisors to modernize and strengthen their marketing. With the ability to solicit honest client reviews and experiences, advisors can build clearer trust with prospects—while staying fully compliant.
To safely unlock these benefits, it’s wise to work with a partner that offers compliant review management. They’ll help you:
- Send invitations to all clients consistently
- Capture and publish reviews with required disclosures
- Archive all communications in line with recordkeeping rules
- Avoid regulatory missteps—like cherry-picking or entangling reviews
Smart advisors are taking action now to automate a fully compliant solutions to give them a competitive advantage and build trust for their services. Consider working with an established partner to build your reputation quickly and grow your client roster through prestige instead of expensive advertising.
