Definition of a Testimonial

• What It Is: A testimonial is any statement from a current client or investor about their experience with your service. This could include opinions on your services, professionalism, or the client-adviser relationship.

• Examples:

  • "Thank you for Not Judging Me”
  • "My advisor always takes the time to explain my options clearly."
  • "Working with this firm has given me peace of mind about my finances."

Requirements for Using Testimonials

To comply with the SEC marketing rule, testimonials must meet the following standards:

• Non-Misleading:

  • Testimonials must reflect the client’s genuine experience and cannot be selectively edited or chosen to misrepresent typical outcomes.
  • Avoid: Claims implying specific investment performance without full context, such as "My portfolio grew 50% in a year!" unless accompanied by detailed substantiation and disclaimers. Actually we don’t talk performance at all, let’s be real.
  • Use: Statements about service quality or the advisory relationship, like "My advisor helped me plan for retirement with confidence."

• No Compensation: we do not authorize the use of compensation (e.g., a discount or gift) for providing a testimonial.

• Disclosure Requirements

  • Clearly state that the testimonial comes from a current client.
  • Note any material conflicts of interest (e.g., if the client is a relative or business partner of the adviser).
  • Include a disclaimer that the testimonial is not indicative of all clients’ experiences and does not guarantee future results or success.

• Fair and Balanced Presentation:

  • Testimonials should not exaggerate your capabilities or create unrealistic expectations. Pair them with broader marketing content that provides a balanced view of your services.

Best Practices

• Focus on Service: Highlight testimonials that emphasize your approach, responsiveness, or trustworthiness rather than specific financial outcomes.