The rule: testimonials are allowed, with disclosures beside them
Under the SEC Marketing Rule, an advisor's website, ads and social posts may quote clients and others, if each quote carries its disclosures (17 CFR 275.206(4)-1(b)).
| Must say, clearly and prominently | Example wording |
|---|---|
| Whether the person is a current client (testimonial) or not (endorsement) | "Current client." |
| Whether they were paid, in cash or otherwise | "Not paid." or "Received a $50 gift card." |
| Any material conflict of interest | "Is the advisor's brother-in-law." |
If the person is paid, you must also disclose the material terms of the pay and describe the conflicts, though not necessarily beside the quote ((b)(1)(ii)–(iii)).
The rule's words:
"That the testimonial was given by a current client or investor, and the endorsement was given by a person other than a current client or investor, as applicable" (17 CFR 275.206(4)-1(b)(1)(i)(A))
"Clearly and prominently" means inside the testimonial, at least as visible as the quote. SEC examiners flagged advisers that "used hyperlinked disclosures rather than including the required clear and prominent disclosures within the testimonial or endorsement", and disclosures "in a smaller or lighter font" (SEC Risk Alert, Dec. 16, 2025).
Everything else on the page must also be fair: no claim you can't prove on demand, and no benefit without its material risks (275.206(4)-1(a)(2) and (a)(4)).
Does the SEC rule cover you?
It covers advisers registered, or required to register, with the SEC (275.206(4)-1).
| You are | Your testimonial rule |
|---|---|
| SEC-registered adviser (generally required over $110 million managed) | SEC Marketing Rule (SEC) |
| State-registered adviser (generally under $100 million, which is barred from SEC registration) | Your state's rule. On May 4, 2026 NASAA's members amended its model rules to "provide a framework for states to permit state-registered investment advisers to utilize testimonials, endorsements, and specific performance reporting within specified guardrails" (NASAA). A model rule binds no one until your state adopts it, so check your state securities regulator. |
| Broker-dealer representative | FINRA Rule 2210: a testimonial about advice or performance must disclose that it may not be representative, is no guarantee, and was paid if over $100 (FINRA 2210(d)(6)) |
| Advisor in Canada | Not the SEC rule. Ask your firm's compliance team which Canadian rules cover your ads. |
Can I put Google reviews on my website?
Yes, but once on your site they are your testimonials and need the disclosures. Examiners saw advisers that copied "current client testimonials or former client endorsements from third-party websites onto the advisers' websites without clearly and prominently disclosing that those testimonials and endorsements were provided by current or former clients" (SEC Risk Alert).
Showing only the five-star ones also makes them yours. The SEC said it would attribute reviews to the adviser if it modifies them "by deleting or suppressing negative comments or prioritizing the display of positive comments" (IA-5653).
Can I ask clients to leave reviews?
Reviews clients post on their own aren't your advertising, as long as you don't filter, edit or help write them:
"permitting all third parties to post public commentary to the adviser's website or social media page would not, by itself, render such content attributable to the adviser, so long as the adviser does not selectively delete or alter the comments or their presentation and is not involved in the preparation of the content." (IA-5653)
Paying for reviews changes that. Examiners flagged advisers that gave clients gift cards to write reviews on third-party sites without a reasonable basis to believe the reviews complied (SEC Risk Alert). Any payment must be disclosed. Over $1,000 to one person in 12 months, you also need a written agreement and a check that the person isn't disqualified (275.206(4)-1(b)(2)–(4), (e)). Google has its own review rules too (see asking for reviews).
Ratings, awards and "Top Advisor" logos
A third-party rating needs, clearly and prominently: the date given, the period it covers, who created it, and whether you paid for it (275.206(4)-1(c)). You also need a reasonable basis to believe its survey was equally easy to answer favourably or not. Examiners saw logos that didn't identify who made the rating, and links to award pages where neither site carried the disclosures (SEC Risk Alert).
Showing performance on your website
| You show | Also required |
|---|---|
| Gross returns | Net returns, equally prominent, same period and method ((d)(1)) |
| Any portfolio's returns (private funds aside) | 1-, 5- and 10-year periods, ending no earlier than the last calendar year-end ((d)(2)) |
| One holding or a slice of a portfolio | The whole portfolio's results, shown or offered ((d)(5)) |
| Hypothetical or back-tested results | Policies that keep it relevant to the audience, plus the assumptions and risks ((d)(6)) |
| "Reviewed by the SEC" | Never allowed ((d)(3)) |
Example
A review carousel
An SEC-registered firm with USD 300 million under management shows 12 Google reviews on its home page. Each card adds, in the same font size: "Current client. Not paid. No conflicts." It shows every review, not only the best.
A referral thank-you
A firm gives each client who refers a friend a USD 100 dinner card. A referral by a client is itself a testimonial, so each friend must be told, when referred, that the referrer is a client, is paid a USD 100 card, and any conflict. A client who refers three friends in a year gets USD 300: under the USD 1,000 line, so no written agreement is needed.
A state-registered planner
A planner with USD 40 million under management registers with her state. Before adding testimonials she checks her state regulator's current rule, since the SEC rule doesn't cover her and her state may not have adopted the NASAA model yet.
Different for you?
- Running Meta ads for financial services: Meta special ad categories.
- Getting more Google reviews within the platform's rules: asking for reviews rules.
- Building the page an ad sends people to: Google Ads landing page.
- A website that shows reviews with the right disclosures and books calls: Website agent.