Rule 206(4)-1(b)(1)(i)(A)

Testimonial/endorsement: required disclosure of client / non-client status

testimonialendorsementdisclosurecurrent-client

Excerpted verbatim from the rule

An advertisement may not include any testimonial or endorsement, and an adviser may not provide compensation, directly or indirectly, for a testimonial or endorsement, unless the adviser discloses, or reasonably believes that the person giving the testimonial or endorsement discloses, the following at the time the testimonial or endorsement is disseminated: That the testimonial was given by a current client or investor in a private fund advised by the investment adviser, and the endorsement was given by a person other than a current client or investor in a private fund advised by the investment adviser, as applicable.

Source: 17 CFR § 275.206(4)-1 on eCFR.

What violations look like

"Working with Harbor Ridge has been life-changing." — Jane R.

Why it's flagged: A testimonial must clearly disclose whether the speaker is a current client of the adviser. Just initials and a first name don't satisfy this — there's no way for a reader to know if Jane is a client.

Compliant rewrite

"Working with Harbor Ridge has been life-changing." — Jane R., a current client of Harbor Ridge.

Run Rule 206(4)-1(b)(1)(i)(A) on your own copy.

Paste any draft — LinkedIn post, newsletter, website copy — and Safe to Publish flags the Rule 206(4)-1(b)(1)(i)(A) issues with citations to the rule and a suggested rewrite.

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This page is for educational purposes and is not legal advice. Safe to Publish is not a law firm. Compliance decisions remain the responsibility of the registered investment adviser. See Terms.