Financial Advisor Marketing Agency.

The SEC's Marketing Rule turned five years old in November 2022, and its December 2025 exam risk alert makes clear the agency is still finding the same basic testimonial-disclosure failures at registered advisers today. For an RIA, that's not a compliance footnote — it's the actual shape marketing has to take.

Financial advisor marketing operates under a rule that's simultaneously more permissive and more exacting than what came before it. Before the 2020 amendments, SEC-registered advisers were effectively barred from using client testimonials at all; the current Marketing Rule opened that door, which is why LinkedIn content, client-story case studies, and third-party ratings have become far more common in RIA marketing since 2022. But the December 2025 exam risk alert shows the SEC actively checking whether that new latitude is being used correctly, and finding it isn't, in specific and recurring ways: disclosures that don't say whether the endorser was paid, disclosures buried where a prospective client won't actually see them, and — increasingly — advisers not recognizing that a social media influencer partnership, a lead-generation vendor relationship, or a 'refer-a-friend' program each independently triggers the same disclosure and written-agreement requirements as a traditional paid testimonial. That last point matters most for growth-stage RIAs, since the arrangements most likely to trigger an unrecognized violation are exactly the modern lead-generation and influencer tactics a marketing-forward advisor is most tempted to try. A compliant system for this vertical builds the disclosure language, the written agreements, and the ineligible-person screening into the marketing process itself, rather than treating compliance as a review step applied after content is already written and a partnership is already live.