Safe to Publish reviews your drafts against the SEC Marketing Rule before you ship them. Paste a LinkedIn post, newsletter, or pitch deck — in about 30 seconds, every clause an examiner could cite, with the exact rule section, staff FAQ, or risk alert behind each flag.
Rule 206(4)-1 — the SEC Marketing Rule — governs every public-facing communication from an SEC-registered investment adviser. The rule sets seven general prohibitions covering untrue statements, unsubstantiated claims, omitted material facts, and unfair presentation of benefits and risks. Each is enforceable as a standalone violation, even where the rest of the piece is clean (§275.206(4)-1(a)(1)–(7)).
Testimonials and endorsements are permitted, but only with prescribed disclosures. The piece must say clearly whether the speaker is a current client, whether they were compensated, and any material conflicts of interest. A LinkedIn post that quotes a client without these disclosures sits inside the rule whether or not the firm calls it a testimonial (§275.206(4)-1(b)(1)).
Performance presentation is the densest part of the rule. Gross-only returns are prohibited unless net-of-fees figures are shown with equal prominence. Hypothetical and backtested performance trigger a separate set of pre-conditions — the adviser must have policies for who the projection is shown to and what disclosures travel with it (§275.206(4)-1(d)(1) and (d)(6)).
The same workflow whether you ship one post a week or a hundred a month.
LinkedIn post, newsletter, pitch deck, RFP language — any pre-publication marketing piece. We accept up to 40,000 characters on the Firm plan.
Every flagged clause links to the SEC Marketing Rule section, the IM staff FAQ, or the Risk Alert behind it. Flags that can't cite an authority are dropped before you see them — no hallucinated section numbers.
Every review is signed, timestamped, and retained — up to 7 years on the Practice and Firm plans. Exportable as a PDF exhibit if a deficiency letter lands.
“Our model has delivered 28% net returns last year — risk-free, guaranteed for clients across every market regime.”
§275.206(4)-1(a)(1) · (a)(2)Untrue statement of material fact and unsubstantiated claim. “Risk-free” and “guaranteed” performance language has no reasonable basis under the rule.Real language patterns that surface in SEC sweep exams, mapped to the section of the rule that catches each one. Examples paraphrased from the Division of Examinations Risk Alerts of June 2023, September 2023, and December 2025.
§275.206(4)-1(a)(1)Untrue statement of material fact“Our strategy has outperformed every benchmark over the last decade.”
Absolute claim with no time period, no benchmark named, no source. Examiners cite this as a material misstatement unless the adviser can produce calculations under a standardized methodology.
§275.206(4)-1(a)(2)Unsubstantiated claim“We are the most trusted RIA in the Midwest.”
Superlatives like ‘most trusted,’ ‘best,’ or ‘leading’ require a reasonable basis the adviser can document in writing — not just internal opinion.
§275.206(4)-1(b)(1)Testimonial without required disclosures“One of our clients told us this was the smartest move of her career.”
Testimonials must clearly disclose whether the speaker is a current client, whether they were compensated, and material conflicts. Missing any one of these is a per-piece violation under the rule.
§275.206(4)-1(c)(2)Third-party rating without conditions“Voted Top RIA Firm — Forbes 2024.”
Third-party ratings require the date the rating was given, the period it covers, and disclosure of any cash or non-cash compensation tied to participation in the rating. The December 2025 Risk Alert flagged the absence of these as a recurring deficiency.
§275.206(4)-1(d)(1)Gross-only performance“Returns: 18.4% annualized since inception.”
Net-of-fees performance must appear with at least equal prominence to any gross figure. A single bolded gross number with the net buried in a footnote does not satisfy ‘equal prominence.’
§275.206(4)-1(d)(6)Hypothetical or backtested performance“Our model would have delivered 24% had it been in market since 2015.”
Hypothetical and backtested performance trigger pre-conditions under the rule: written policies for distribution, an intended audience that can independently evaluate the projection, and disclosures sufficient for the recipient to understand the assumptions and limitations.
Want the full rule with every cited section in plain English? Read the full Rule 206(4)-1 guide →
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