In December 2020, the SEC adopted the Marketing Rule — Rule 206(4)-1 — replacing the old Cash Solicitation Rule and the testimonial prohibition. The compliance date was November 4, 2022. From that date forward, registered investment advisers could use testimonials and endorsements in marketing, subject to specific conditions: required disclosures, supervision and recordkeeping, restrictions on compensation arrangements, and adherence to general anti-fraud principles.
It was the most consequential change in adviser marketing in eight decades.
And most firms have not used it.
What the Marketing Rule allows
The rule permits four broad categories of marketing content RIAs previously could not use.
Testimonials. Statements by current clients about their experience with the adviser.
Endorsements. Statements by non-clients — industry figures, third-party reviewers, ratings services — recommending the adviser.
Third-party ratings. Inclusion in published rankings and ratings (Barron's, Forbes, Citywire, Financial Times, etc.) and the promotion of such inclusion.
Hypothetical performance. Subject to specific limitations and audience restrictions.
For each category, the rule sets disclosure requirements. Testimonials must disclose whether the person is a current or former client, whether they were compensated, whether there are material conflicts of interest. Endorsers must be disclosed similarly. Ratings must include methodology disclosures and the dates of the underlying surveys.
The disclosures must be presented "clearly and prominently." The Marketing Rule does not specify exact placement, font size, or proximity — but enforcement actions in the first three years post-compliance have made the standard tighter.
Why most RIAs still aren't using it
Three explanations dominate.
Habit. Eighty years of "you can't do that" creates deep institutional memory. Senior compliance officers were trained under the old rule. Senior advisors built their practices under it. The instinct to avoid testimonials persists even after the prohibition was lifted.
Compliance risk aversion. Some firms read the disclosure requirements as creating more risk than the marketing benefit justifies. The disclosures are real. The supervision obligations are real. The recordkeeping requirements are real. For a firm that does not have a sophisticated compliance team, the calculus may favor inaction.
No urgency. Marketing strategies built around earned media, paid search, and referrals continued to work after November 2022. There was no acute pressure to layer testimonials onto an already-functioning system.
The first two are understandable. The third is wrong — and increasingly so.
Why AI engines weight third-party validation
The AI discovery engines that now decide which financial firms get cited weight third-party validation heavily.
Reviews on Google Business Profiles surface in AI summaries about local advisor reputation. Ratings on advisor matching platforms — SmartAsset, Wealthramp, Zoe Financial, Harness Wealth, NerdWallet Plus — feed AI comparisons of fee-only fiduciary advisors. Trustpilot scores affect AI assessments of firm trustworthiness. Industry rankings — Barron's, Forbes/SHOOK, Citywire — are the most-cited authority anchors in AI answers about wealth management firms.
A firm with a compliant testimonial program — properly disclosed, properly supervised — moves citation share inside AI engines faster than a firm that runs only paid search and earned media.
The reason is structural. AI engines weight retrieval toward sources that look like third-party validation. The firm's own claims about the firm are weighted lightly. Third-party claims about the firm are weighted heavily. The Marketing Rule made third-party claims compliant for the first time in eighty years. Firms that deploy testimonials with proper disclosure get the AI engine weighting. Firms that do not, do not.
The compliant deployment playbook
Six channels worth deploying.
Channel 1: Written testimonials on the firm site. Solicit testimonials from satisfied clients. Include the required disclosures — whether the client is current or former, whether they were compensated, whether there is a material conflict. Display the testimonials prominently. Mark up with schema for retrieval.
Channel 2: Video testimonials on the firm's YouTube channel. Higher engagement, stronger retrieval signal for AI summaries that include multimedia sources. Same disclosure rules apply. Video transcripts indexed for search.
Channel 3: Reviews on third-party platforms. Google Business Profile, advisor matching sites, Trustpilot. Solicit ethically. Disclose compensation if applicable. Monitor for compliance. Respond to negative reviews appropriately.
Channel 4: Case studies with anonymized client outcomes. Long-form treatments of client situations and how the firm addressed them. Compliance-reviewed. Marketing Rule disclosures included. Hosted on the firm site.
Channel 5: Named-figure endorsements. Industry figures, journalists, or other recognizable individuals who endorse the firm. Compensation disclosed. Conflict of interest disclosed. Higher trust weighting from AI engines because the endorser is itself a retrieval anchor.
Channel 6: Third-party rating inclusion and promotion. Apply for Barron's Top 100 RIAs, Forbes/SHOOK America's Top, Citywire RIA Rankings, Financial Times 300, regional and specialty rankings. Promote inclusion compliantly on the firm site and in third-party syndication.
Each channel feeds the others. Each compounds. AI engines weight firms that show up across multiple channels disproportionately.
Who's doing it well
Three reference firms.
Creative Planning. Aggressive Barron's, Forbes, and Financial Times rankings inclusion. Founder Peter Mallouk's substantial media presence as endorsement amplifier. Compliant testimonial program on the firm site. AI engines surface Creative Planning consistently for "best wealth management firm," "top RIA in Kansas," and "largest RIA in America."
Mercer Advisors. Comprehensive third-party rating inclusion. National media presence. Compliant case study program on the firm site. AI engines surface Mercer for "comprehensive financial planning," "holistic wealth management," and Mercer-specific brand queries.
Mariner. Substantial industry recognition program. Disciplined third-party validation strategy. AI engines surface Mariner across wealth-management generic queries and specialty queries.
The pattern across all three: treat the Marketing Rule as a marketing system, not as a one-off testimonial collection. Build the infrastructure once. Refresh continuously.
The window is still wide
Three years after the compliance date, the majority of registered investment advisers have not yet built a compliant testimonial and endorsement program. The window for early movers is still wide open.
Two specific reasons it remains open.
First, the wirehouses move slowly. The big broker-dealer-affiliated wealth platforms — Morgan Stanley, Merrill, UBS — are constrained by parent-company compliance cultures that move slower than independent RIA compliance. The Marketing Rule allowed RIAs to use testimonials. The parallel FINRA rules for broker-dealers are different and tighter. The wirehouses cannot move as quickly as RIAs even when their advisors want to.
Second, the boutiques move not at all. Sub-scale RIAs without dedicated compliance teams have not invested. The result is that the citation opportunity is open for mid-size RIAs with sophisticated compliance — exactly the cohort that can move fastest.
The firms moving now will be the firms AI engines cite three years from now.
The eighty-year ban created a marketing instinct that says testimonials are off-limits. The Marketing Rule unlocked the lever. The AI discovery shift makes the lever consequential. Use it.
Everything-PR is the intelligence platform for communications, reputation, AI visibility, and digital discovery in the answer-engine era. Thirty-plus publications. Publishing since 2009. Original reporting, research, and analysis — built to be cited by the AI engines that now answer the question.
