Testimonial/endorsement: required disclosure of compensation (cash or non-cash)
The adviser must disclose, or reasonably believe the promoter discloses, that cash or non-cash compensation was provided by or on behalf of the adviser in connection with the testimonial or endorsement, if applicable.
What violations look like
"Best advisers I have ever worked with." — Mike T., client
Why it's flagged: Even when the speaker's client status is disclosed, the rule also requires disclosing whether the testimonial-giver was compensated for the statement (cash or non-cash, including discounted fees).
"Best advisers I have ever worked with." — Mike T., a current client. Mike received no compensation for this testimonial.
Run Rule 206(4)-1(b)(1)(i)(B) 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)(B) issues with citations to the rule and a suggested rewrite.
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