Let’s establish a consistent and compliant oversight framework for third-party lead generation and advisor profile platforms that feature individual IARs in exchange for compensation.

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These arrangements are governed by the SEC’s Marketing Rule 206(4)-1 and are considered promoter relationships.

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This applies to any third-party service that:

  1. Features or promotes an Investment Adviser Representative (IAR);
  2. Provides prospective client leads or referrals; and
  3. Uses testimonials, endorsements, or appearance of approval in its public-facing communications.

🔷 This includes, but is not limited to, digital lead-gen platforms, advisor directories, vetting networks, or paid content features that promote IARs to prospective clients.

Compensation Structure

The IAR—not the RIA—is responsible for all costs and compensation associated with participation in these programs.

This may include: