Can You Use Client Testimonials on Your Advisor Website? Here Is What the Rules Allow

For a long time, the answer was a hard no. Investment advisers could not use client testimonials in advertising, full stop. That rule was written in a different era, and the SEC replaced it with the Marketing Rule, which firms had to follow starting in November 2022. Today you can put a client's words on your website. You just have to do it correctly, and plenty of firms are still getting it wrong. SEC exam staff have flagged testimonial and endorsement problems in several risk alerts since the rule took effect.

What counts as a testimonial

A testimonial is any statement by a current client or investor about their experience with you. A statement by someone who is not a client, say a referral partner, a CPA, or a centers-of-influence contact, is an endorsement. The rules for the two are nearly identical, so do not lose sleep over which bucket a quote falls in. Focus on the disclosures.

It also matters where the words come from. A quote you place on your homepage is clearly your advertisement. Content on a third-party site can become yours too if you get involved in it, for example by editing it, asking only happy clients to post, or featuring only the positive reviews. We cover that below.

The three disclosures you cannot skip

Whenever you feature a testimonial or endorsement, you must clearly and prominently tell the reader three things:

• Client status. Whether the person is a current client or investor, or not.
• Compensation. Whether they were paid or received anything of value for the statement, in cash or otherwise.
• Conflicts. A brief statement of any material conflict of interest arising from your relationship with them.

"Clearly and prominently" is doing real work in that sentence. The disclosure has to sit with the testimonial, at least as noticeable as the quote itself, where a visitor will actually see it. A footnote in light gray at the bottom of the page, or a link to a policy page, does not meet that standard. Additional details, like the material terms of any compensation arrangement, also need to be disclosed, though they can sit a step away.

A simple format works well on a website. Put the quote, the person's first name or initials, and then a short line beneath it such as "Current client. No compensation was provided for this statement." Adjust the wording with your compliance resource to fit each situation.

If money changes hands, add paperwork

Paying for a testimonial or endorsement is allowed, but it triggers extra obligations. If you pay a promoter more than $1,000 in value over a twelve-month period, you need a written agreement that describes the activities and the terms of compensation. You also cannot compensate someone who is subject to certain disqualifying events, such as specific regulatory orders or convictions within the look-back period. And regardless of payment, you need a reasonable basis to believe every testimonial or endorsement you use meets the rule, which means some level of oversight.

Unpaid, genuine client quotes are far simpler, which is why most advisors start there. Note that "compensation" is broad. A gift card, a discount on fees, or a referral bonus all count.

Scenario checklist

• ☐ Unpaid client quote on your site. The three disclosures, placed with the quote, plus a reasonable basis to believe it meets the rule.
• ☐ Client who received a small thank-you gift. Same as above, and the disclosure must say the person was compensated.
• ☐ Paid referral partner or solicitor. Disclosures, plus a written agreement above $1,000 a year and a disqualification check.
• ☐ Star rating or "Top Advisor" badge. Disclose the date, the period covered, who produced it, and whether you paid to be included.
• ☐ Link to an independent review site. Generally lower risk when you do not edit, filter, or selectively promote the reviews; confirm your firm's approach.
• ☐ Curated reviews displayed on your homepage. Treat them as your own testimonials, with full disclosures.
• ☐ Video testimonial. Disclosures shown on screen or directly beside the video, not only in a description field.

Reviews on third-party sites

Google, Facebook, and industry review platforms raise their own questions. The general principle is adoption and entanglement. If you take a review and feature it, it becomes your advertisement. If you help write it, edit it, or systematically ask only your happiest clients to post, you are entangled with it and it may be treated as yours. A plain link to an independent review profile, where anyone can post and you do not filter what shows, is generally viewed as lower risk. Firms differ on how they handle this, so agree on a policy with your compliance team before you add review widgets to your site.

If you are also a broker or insurance producer

The Marketing Rule covers investment advisers. If you are dually registered, broker-dealer communications fall under FINRA Rule 2210, which has its own testimonial requirements, including disclosures that the statement may not represent other customers' experiences, is no guarantee of future performance or success, and, above a small amount, that it was paid for. If you sell insurance or annuities, state insurance advertising rules apply to testimonials used in that part of your business, and your carriers or IMO may have their own approval process. When one website covers several lines of business, make sure each testimonial is reviewed under every set of rules that touches it. Our guide to insurance and annuity marketing rules covers the state side.

The mistakes that get flagged

The common ones are easy to avoid once you know them:

• Presenting a handful of glowing quotes as if they represent every client's experience.
• Editing a quote in a way that changes its meaning or strength.
• Showing a rating badge without the date, period, and source.
• Treating the disclosure as fine print that visitors have to hunt for.
• Paying a promoter without a written agreement once compensation passes the threshold.
• Losing track of which quotes were approved and when.

A practical way to start

Reach out to three or four clients who like working with you. Ask for a specific, honest sentence or two about an experience, not a promise of returns. Get their permission in writing to use it publicly. Add the client-status and compensation disclosures right beneath each quote. Run the final version past your CCO or compliance consultant. Then keep a record: the original statement, the approval, the date it went live, and the page where it appears. Done this way, testimonials become one of the most persuasive things on your site, and they hold up under a compliance review.

For a broader pass over your site, use our SEC Marketing Rule website checklist and our guide to where disclosures belong. If you would rather have testimonials designed in with the disclosures built into the layout, see how we work with RIAs and fee-only planners.

This article is general information, not legal or compliance advice. Confirm any specific requirement with your firm's CCO or compliance counsel before you publish.