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

Testimonial/endorsement: required disclosure of material conflicts of interest

testimonialendorsementconflictsdisclosure

Excerpted verbatim from the rule

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.

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

What violations look like

Website

"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.

Compliant rewrite

"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.

Run Rule 206(4)-1(b)(1)(i)(C) 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)(C) issues with citations to the rule and a suggested rewrite.

Start free trial →

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.