Financial Advisor Reviews: SEC and State Rules Explained

Client reviews and testimonials can underscore your credibility as an advisor and help attract new prospects to your firm. The SEC’s marketing rule permits the use of financial advisor reviews in marketing materials, with some stipulations. However, individual states may restrict or prohibit the use of reviews for promotional purposes. Reviewing the latest guidelines for your state can ensure compliance with marketing regulations.

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Financial Advisor Reviews: SEC vs. State Rules

The SEC’s marketing rule, which took effect in 2021, allows advisors to use reviews and testimonials in marketing materials. This includes reviews from clients as well as endorsements from non-clients, such as centers of influence or industry professionals. These rules apply to SEC-registered investment advisors.

Recognizing the need for alignment with SEC standards, the North American Securities Administrators Association (NASAA) proposed a rule change that would allow state-registered advisors to use testimonials, endorsements and specific performance reporting within a compliant framework. In May 2026, NASAA voted to pass the amendments but individual states can decide whether to adopt the new rules. ¹

As of November 2026, 11 states explicitly prohibited smaller advisory firms from publishing client reviews while allowing it for larger firms, according to research from Wealthtender. For the purposes of Wealthtender’s research, “small” means a state-registered firm while “large” means SEC-registered. ² Another 10 states have laws on the books prohibiting reviews, but have agreed to grant leeway to advisors in light of the NASAA amendments or are likely to adopt the new rules. Other states are tentatively or actively moving toward adoption.

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State Rules for Financial Advisor Reviews (2026)

State-registered advisors and those starting an RIA who plan to register at the state level should be aware of the latest rules regarding reviews and testimonials. Below is a comparison of how rules vary for all 50 states and the District of Columbia, according to Wealthtender data:

Each state’s timeline for adopting the updated NASAA rules will vary and in some states, reviews may remain prohibited indefinitely. Checking with your state’s regulatory agency can help you determine the most up-to-date guidance on what is or is not allowed regarding reviews and testimonials.

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Compliance Rules for Financial Advisor Reviews

If you’re SEC-registered or registered in a state that follows the SEC’s marketing rule, you can use reviews, endorsements and testimonials to market your business, but you must do so compliantly. Here’s what’s required:

Disclosures

Financial advisors who use testimonials or endorsements in their marketing must provide information about the reviewer’s relationship with the firm. This includes identifying whether the person is a current client or non-client, disclosing any cash or noncash compensation they received and describing any material conflicts of interest tied to the relationship or compensation.

Certain disclosures must be clear and prominent so prospective clients can easily find them. Concealing required information behind hyperlinks or displaying it in small, difficult-to-read text may violate the SEC’s marketing rule.

Written Agreements

If an advisor pays a promoter more than $1,000 over a rolling 12-month period for reviews or testimonials, there must be a written agreement in place detailing the arrangement. Written agreements are generally not required for compliance for affiliated personnel when the relationship is clear or has already been disclosed.

Ineligible Persons

The SEC’s marketing rule restricts advisors from compensating certain individuals for testimonials or endorsements if they have a history of specified disciplinary actions or other disqualifying events. Advisors must take reasonable steps to determine whether a compensated promoter is eligible, although exceptions apply in certain circumstances.

Third-Party Reviews and Ratings

Advisors may also use reviews from third-party websites in their marketing, assuming they comply with applicable testimonial and endorsement requirements. The SEC has separate rules for third-party ratings, such as rankings or scores issued by independent organizations.

When advertising a third-party rating, advisors generally must disclose when the rating was issued, the period it covers, who created it and whether the advisor paid to obtain or use it. Advisors should also have reason to believe that the rating was based on a survey that didn’t favor positive reviews or discourage negative feedback.

Other Compliance Requirements

The marketing rule bars advisors from making any false or misleading statements in their marketing materials. They can’t include any unsubstantiated claims, including claims made in reviews, without providing evidence to back them up. Advisors must give all of their clients an opportunity to share a review; cherry-picking is not allowed and negative reviews can’t be deleted or ignored.

SEC-registered advisors must report certain marketing activities, including their use of testimonials, endorsements and third-party ratings, on Form ADV. They must also maintain records of advertisements they disseminate, including client testimonials used in those materials. These records generally must be retained for at least five years, measured from the end of the fiscal year in which the advertisement was last disseminated.

Frequently Asked Questions (FAQs)

Bottom Line

Financial advisor reviews can strengthen your marketing but it’s important to adhere to compliance rules when using them. If you’re a state registered advisor who is currently prohibited from leveraging reviews or testimonials, consider how you can fill the gap elsewhere in your marketing plan. For example, developing a thought leadership strategy or hosting educational seminars could raise your profile among the ideal clients you hope to target.

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• If you’re starting a new RIA with $0 AUM, you’ll need to register at the state level. If AUM is between $100 million and $110 million, you have the option to register with the state or the SEC. Once registered, it’s important to keep up with annual filing deadlines. For example, annual Form ADV updates are required within 90 days of the end of your fiscal year regardless of whether you’re state or SEC-registered.

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