For SEC-registered investment advisers, your website is regulated marketing — and the rule that governs it is the SEC Marketing Rule. It decides how testimonials and reviews can appear on your site, how performance can be shown, and what claims your copy can make. This is a plain-English overview of what that means for your website.

One important note up front: this is a general overview for business owners, not legal or compliance advice. The Marketing Rule is detailed, facts-specific, and consequential — every decision about your site's content should go through your firm's compliance counsel or chief compliance officer. The job of a good web partner is to build a site that supports your compliance obligations, working alongside your compliance team rather than around them.

I'm David Campbell, founder of Nerd Stack. We build websites for financial firms, so we work inside these constraints regularly. Here's what advisory-firm owners should understand about the Marketing Rule before they build or redesign a website.

What Is the SEC Marketing Rule?

The SEC Marketing Rule — formally Rule 206(4)-1 under the Investment Advisers Act — is the regulation that governs how SEC-registered investment advisers advertise. It was adopted in December 2020 and carried a compliance date of November 4, 2022, replacing decades-old advertising and solicitation rules with a single, modernized framework.

"Advertising" under the rule is broad, and it plainly includes your website. Your homepage copy, your service descriptions, any testimonials or reviews, any performance figures, your blog — all of it can fall within the rule's scope. (The rule applies to SEC-registered advisers; state-registered advisers face their own state rules, which often echo it. Your compliance team will know exactly where your firm stands.)

The Seven General Prohibitions

At the core of the rule are seven general prohibitions. In plain terms, your website's marketing content cannot:

  • Include an untrue statement of material fact, or omit a material fact that makes something misleading.
  • Make a material claim or statement you can't substantiate if the SEC asks.
  • Include information reasonably likely to cause an untrue or misleading inference.
  • Discuss potential benefits without fair and balanced treatment of associated risks or limitations.
  • Reference specific advice in a way that isn't fair and balanced.
  • Include or exclude performance results in a way that isn't fair and balanced.
  • Otherwise be materially misleading.

The throughline is "fair and balanced." Marketing copy that trumpets upside while burying risk is the exact pattern the rule exists to stop — and that has direct implications for how confidently your website can be written.

Testimonials and Reviews: Allowed, With Conditions

This is the change most relevant to websites. The old rules effectively banned client testimonials. The Marketing Rule permits testimonials, endorsements, and third-party ratings — which means client reviews can appear on an advisor's website — but only with conditions. The main ones:

  • Clear and prominent disclosure. The ad must disclose whether the person is a client, and whether they were compensated. The SEC has been emphatic that "clear and prominent" is literal — burying a disclosure in a footnote, a hover, a separate page, or small print does not satisfy the rule. The disclosure has to sit with the testimonial.
  • Conflicts and compensation. Additional disclosure is required around compensation and any material conflicts of interest.
  • Oversight and agreements. The adviser must oversee compliance, and generally needs a written agreement with anyone compensated to promote the firm.
  • Disqualification. An adviser can't pay for a testimonial or endorsement from someone subject to certain disqualifying events.

In 2026 the SEC staff published additional Marketing Rule FAQs, and enforcement attention has centered on exactly this area — the most common finding being disclosures that were omitted entirely or simply not "clear and prominent." If you want client reviews on your site, they have to be built in with the disclosures designed from the start, not added as an afterthought.

Performance Advertising

If your website presents any performance results, the rule sets specific conditions — for instance, around showing net performance alongside gross, and presenting time periods fairly. Performance advertising is one of the most technical and most scrutinized parts of the rule. If your site will show performance of any kind, treat it as a compliance-led decision from the first conversation.

What This Means for Building Your Website

You don't need to be a compliance expert to build a good advisor website — but the project has to respect the rule. In practice:

  • Compliance reviews the content. Website copy is advertising; it goes through the same review as any other marketing. Build that into the project timeline.
  • Testimonials are designed, not bolted on. If reviews will appear, the disclosures are designed to sit clearly and prominently with them from the start.
  • Claims are substantiated. Every material claim in the copy should be something the firm can back up.
  • Recordkeeping is considered. The rule carries recordkeeping obligations — including for what appeared on your website and when. A good build accounts for keeping that record.
  • The web partner works with your compliance team. Choose a partner who builds to support your obligations and collaborates with your CCO — not one who treats compliance as someone else's problem.

When we built the site for Reichelt Capital, a private investment firm, building with compliance posture in mind — data control, access, keeping confidential material on infrastructure the firm controls — was central to the project, done alongside the firm rather than around it.

Frequently Asked Questions

Does the SEC Marketing Rule apply to my website?

If you're an SEC-registered investment adviser, yes — your website is "advertising" under the rule, including homepage copy, service pages, testimonials, performance figures, and blog content. State-registered advisers follow state rules, which often parallel it. Your compliance team can confirm exactly how it applies to your firm.

Can financial advisors put client testimonials on their website?

Yes — the Marketing Rule permits testimonials, which the old rules effectively banned. But they require clear and prominent disclosure of whether the person is a client and whether they were compensated, plus conflict disclosures, oversight, and written agreements where applicable. The disclosures must sit with the testimonial, not be buried.

What does "clear and prominent" mean for disclosures?

The SEC has been explicit: the disclosure has to be genuinely visible alongside the testimonial. Putting it in small print, a footnote, a hover, or a separate page does not satisfy the rule. On a website, that means designing the disclosure into the testimonial component itself.

Is this blog post compliance advice?

No. This is a general overview for business owners. The Marketing Rule is detailed and facts-specific, and every decision about your website's content should be made with your firm's compliance counsel or chief compliance officer. A good web partner builds to support those decisions, not to replace them.

Whose job is compliance on a website project — mine or the web agency's?

Compliance review is your firm's responsibility, through your CCO or compliance counsel. The web partner's job is to build a site that supports it — designing testimonial disclosures correctly, structuring content for review, and accounting for recordkeeping. The best projects have the two working together from the start.

Bottom Line

For an SEC-registered adviser, the website is regulated marketing, and the SEC Marketing Rule sets the boundaries: fair-and-balanced content, testimonials only with clear and prominent disclosure, performance presented under strict conditions. None of that should stop you from building an excellent website — it just means compliance is part of the project, designed in from the first conversation rather than discovered at launch.

We build financial firm websites with exactly that posture — working alongside your compliance team, not around it. See our financial advisor web design page or book a free call, and read what makes a great financial advisor website for the broader picture.

Sources: SEC — Marketing Compliance Frequently Asked Questions; SEC — Investment Adviser Marketing Compliance Guide.