For registered investment advisers
Use client testimonials under the SEC Marketing Rule
Since the SEC’s Marketing Rule, a registered investment adviser can publish client testimonials, but only with specific disclosures and oversight. Work through the rule’s conditions below, then collect and review each testimonial in StoryProof before your compliance team signs it off.
- The rule’s testimonial conditions as a checklist
- A warning about rewards that count as compensation
- Prompts that stay away from performance
The problem, solved
Where an adviser’s testimonial process breaks, and what StoryProof covers
StoryProof holds the collection and the queue. The compliance judgement stays with your CCO.
Situation 1 of 4
Nothing can go live before compliance reads it
A single client quote published ahead of review can leave the firm without the reasonable basis the rule asks for.
How StoryProof solves it
Client submissions sit unpublished until someone on your team approves them, and with automatic approval left switched off, a five star rating gets no shortcut past the CCO.
Situation 2 of 4
We lose track of which quotes are cleared
Marketing reaches for a quote from last year without knowing whether compliance signed it off or the client has since left.
How StoryProof solves it
Tags come with every plan, so each testimonial can carry its review status and sign-off date where the whole team sees it.
Situation 3 of 4
A thank-you reward turns into compensation
A discount handed out for a testimonial is non-cash compensation, and it changes what has to be disclosed beside the quote.
How StoryProof solves it
A reward code is an optional step on multi-step forms that you add yourself. Build the form without it and clients are offered nothing.
Situation 4 of 4
Disclosures have to sit with the right quote
A disclosure written for one client’s statement means little if the page around it shows a different client.
How StoryProof solves it
Each widget shows only the approved testimonials you pick for it, so the disclosure text in your page copy always matches the quotes beside it.
Checklist
The Marketing Rule’s testimonial conditions
Paraphrased from paragraph (b) of the rule as published on 4 November 2026. Your compliance officer decides how each item is met at your firm. Not legal advice.
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Things on a testimonial form that change the disclosure
Prompts
Prompts that describe the relationship, not the returns
Every one of these asks about service. None invites a client to talk about performance.
After a planning milestone
- How did we help you feel prepared for this decision?
- How do we explain things in a way that works for you?
Leave out
- Returns, account values or comparisons with a benchmark
At an annual review
- What is it like to work with us from year to year?
- How quickly do you hear back when something changes in your life?
Leave out
- Specific holdings or products
In StoryProof
Collect it in StoryProof, sign it off in compliance
- You will need
- Your compliance policy for testimonials
- A StoryProof workspace
- 1
Set up a form with service-only prompts
Clients reply by video, audio note or text from one link. Leave reward codes off unless compliance has agreed how they are disclosed.
- 2
Send the request by email
StoryProof emails the link to clients you choose.
- 3
Keep every submission in the queue
Nothing is published until someone approves it. Do not use automatic approval: every testimonial needs a compliance read, whatever its rating.
- 4
Tag the compliance status
Tag testimonials as pending review, approved or withdrawn, with the approval date, so the library shows what can be used.
- 5
Publish only approved testimonials, with disclosures beside them
Add approved testimonials to a widget and place the required disclosures in your page copy next to it.
What happens next: When a client relationship ends or a disclosure changes, update or remove the testimonial and re-tag it.
Before you start
Honest limits
What this does not cover, and what to check on your side. Better to know now than after launch.
- 01
StoryProof does not do your compliance review
It collects, stores and displays testimonials. Whether a testimonial meets the rule, and what its disclosure says, is your firm’s decision.
- 02
Disclosures live in your page copy
Write the disclosure text on your own page beside the widget, so it is always shown with the testimonial it belongs to.
- 03
Not every firm is under this rule
The Marketing Rule covers SEC-registered investment advisers. Broker-dealers, insurance agents and state-registered advisers follow other rules. Not legal advice.
- 04
Video and audio need their own disclosure
A disclosure beside a written quote is easy to place. For a video or audio note, ask compliance how the disclosure should appear so a viewer meets it with the clip.
FAQ
Questions people ask
Short answers to what usually comes up next.
Can a registered investment adviser use client testimonials?
Yes, under the SEC Marketing Rule, provided the testimonial carries the required disclosures and the firm meets the rule’s oversight conditions.
Does a thank-you gift for a testimonial count as compensation?
The rule refers to cash or non-cash compensation, so a gift or discount should be treated as compensation and disclosed. Confirm the treatment with your compliance officer.
Can I show star ratings from clients?
That is a question for compliance. Many firms show the written testimonial with its disclosures and leave ratings out.
Can a client’s testimonial be published without their name?
That is a decision for your compliance officer. Whatever name is shown, the disclosures about client status and compensation still have to appear with it.
Can we edit a client’s wording before it goes live?
Keep edits to trimming for length and show the client the final version. Compliance should approve the exact wording that is published, and that version is the one to keep in your records.
Still have a question? Ask the StoryProof team or book a demo.
Give compliance a testimonial process to review
Set up a service-only form, collect a first testimonial and walk your CCO through the approval queue.
Sources
- 17 CFR 275.206(4)-1: Investment adviser marketing, Legal Information Institute, Cornell Law School. Checked 2026-11-04.
Last updated 2026-11-04.