Testimonial/endorsement: required disclosure of material conflicts of interest
The adviser must disclose, or reasonably believe the promoter discloses, a brief statement of any material conflicts of interest on the part of the person giving the testimonial or endorsement resulting from the investment adviser’s relationship with such person.
What violations look like
"I would recommend Harbor Ridge to anyone." — David & Linda M., clients since 2014
Why it's flagged: In addition to client status and compensation, any material conflicts of interest between the adviser and the testimonial-giver must be disclosed. Long-tenured clients can have entanglements (board roles, business referrals, family relationships) that need to be surfaced.
"I would recommend Harbor Ridge to anyone." — David & Linda M., current clients since 2014. No compensation was provided. No material conflicts of interest exist between Harbor Ridge and David & Linda M.
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