SEC Marketing Rule (Rule 206(4)-1): The 2026 Complete Guide for RIAs

TL;DR — The SEC Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act) is the principles-based regime that governs how SEC-registered investment advisers communicate with prospective and existing clients. Adopted on 22 December 2020 and effective for full compliance on 4 November 2022, it replaced the old Advertising Rule and the Cash Solicitation Rule with a single framework covering seven general prohibitions, testimonials and endorsements, third-party ratings, performance advertising, and books-and-records retention under Rule 204-2. Enforcement has been steady and pattern-focused: examiners keep finding the same disclosure-at-the-point-of-dissemination failures and the same unsubstantiated performance claims, across both first-time RIAs and large multi-fund complexes. This guide explains the rule in full, walks through the operational programme that survives an exam, and shows where AI-driven review fits in.

Table of contents

• What the SEC Marketing Rule is, and who it applies to
• A short history: how we got to Rule 206(4)-1
• What counts as an "advertisement" under the rule
• The seven general prohibitions
• Testimonials and endorsements
• Third-party ratings
• Performance advertising
• Books and records (Rule 204-2) and Form ADV updates
• Recent enforcement: what the SEC is actually catching
• Building a Marketing Rule compliance programme
• How Sedric helps RIAs comply with the Marketing Rule
• FAQ

What the SEC Marketing Rule is, and who it applies to

The SEC Marketing Rule — formally Rule 206(4)-1 under the Investment Advisers Act of 1940, codified at 17 CFR 275.206(4)-1 — governs how SEC-registered investment advisers (RIAs) communicate with prospective and existing clients, private fund investors, and the broader market. It applies to every form of advertising an RIA produces: websites, social media, paid digital, video, podcasts, investor letters, pitch decks, RFP responses, third-party endorsements, finfluencer arrangements, and rated lists.

It applies directly to SEC-registered investment advisers. State-registered advisers are subject to the analogous rules of their state regulator, which in most cases mirror or align with the SEC framework but can add their own conditions. Broker-dealers remain subject to FINRA Rule 2210 for communications with the public, but dual-registrants (firms registered with both the SEC as advisers and FINRA as broker-dealers) must comply with both regimes, and the practical effect for most dual-registrants is that the higher standard governs each piece of content.

The rule replaced the previous Advertising Rule, which had governed adviser advertising since 1961, and the Cash Solicitation Rule (Rule 206(4)-3), which had governed payment to non-clients for client referrals. Both were replaced by a single, principles-based rule effective on 4 November 2022.

A short history: how we got to Rule 206(4)-1

The old Advertising Rule was adopted in 1961 and remained substantively unchanged until 2022. Over six decades, SEC staff issued no-action letters and interpretive guidance that, in practice, defined what advisers could and could not say. The result was a patchwork: testimonials were effectively prohibited by staff position, performance advertising was governed by a series of letters known collectively as the "Clover Capital" framework, and the use of past specific recommendations was constrained by a no-action position predating the internet.

By the 2010s the regime was out of step with how advisers actually marketed, with how clients consumed content, and with the digital channels (search, social, podcasts, video) that had become the dominant route to prospective investors. Testimonials and third-party ratings were ubiquitous in adjacent industries; for RIAs they remained off-limits under the old letter regime.

The SEC proposed a comprehensive rewrite on 4 November 2019, adopted the final rule on 22 December 2020, and gave advisers an 18-month transition period to update policies, procedures, and form filings. The compliance date for the new rule was 4 November 2022. From that date, the old rule and its no-action letter scaffolding were withdrawn, and advisers were expected to operate on the new principles-based regime.

The rule is widely regarded as the most significant change to adviser advertising in over sixty years. It opened the door to compensated testimonials and endorsements, codified performance advertising standards, brought third-party ratings inside the rule, and imposed a robust books-and-records regime for everything the adviser publishes.

What counts as an "advertisement" under the rule

The rule defines "advertisement" in two prongs.

The first prong: any direct or indirect communication an investment adviser makes that offers the adviser's investment advisory services with regard to securities to prospective clients or investors in a private fund, or offers new advisory services to current clients or investors. Communications to a single prospective client are not advertisements; communications to one or more is. Live extemporaneous oral communications are excluded; pre-recorded video, podcasts, and webinars are not.

The second prong: any endorsement or testimonial for which the adviser provides cash or non-cash compensation, directly or indirectly. This is the prong that brought finfluencer arrangements, paid promoters, and compensated third-party reviewers squarely inside the rule. The communication does not need to mention the adviser by name to qualify as an endorsement or testimonial if the adviser is the implicit subject and the speaker is compensated.

The definition excludes:

• Extemporaneous, live, oral communications.
• Information contained in a statutory or regulatory notice, filing, or other required communication (e.g. Form ADV itself).
• A communication that includes hypothetical performance provided in response to an unsolicited request from a prospective or current client or investor, subject to conditions.
• A communication that includes hypothetical performance provided to a prospective or current private fund investor in a one-on-one communication.

The two-prong structure matters operationally. The first prong picks up everything an adviser publishes about itself; the second picks up anything paid third parties publish about the adviser. A compliance programme has to cover both surfaces.

The seven general prohibitions

Rule 206(4)-1(a) prohibits an advertisement that:

1. Makes an untrue statement of a material fact, or omits to state a material fact necessary in order to make the statement made, in light of the circumstances under which it was made, not misleading.
2. Includes a material statement of fact that the adviser does not have a reasonable basis for believing it will be able to substantiate upon demand by the SEC.
3. Includes information that would reasonably be likely to cause an untrue or misleading implication or inference to be drawn concerning a material fact relating to the adviser.
4. Discusses any potential benefits without providing fair and balanced treatment of any associated material risks or limitations.
5. References specific investment advice provided by the adviser that is not presented in a fair and balanced manner.
6. Includes or excludes performance results, or presents performance time periods, in a manner that is not fair and balanced.
7. Is otherwise materially misleading.

The prohibitions are deliberately principles-based. "Fair and balanced," "reasonable basis," and "materially misleading" are the operative standards, and the SEC has been clear that examiners will assess them holistically, considering the audience, the channel, and the context of the communication.

The seventh prohibition is the catch-all that examiners reach for when the violation does not fit cleanly into the first six. In practice, the most-cited prohibitions in enforcement to date are #1 (untrue or unsubstantiated statements) and #4 (potential benefits without fair and balanced treatment of risks).

Testimonials and endorsements

The Marketing Rule formally permits both testimonials and endorsements for the first time since the 1971 no-action regime, subject to a robust set of conditions in Rule 206(4)-1(b).

Definitions

A testimonial is any statement by a current client or private fund investor about the client's experience with the adviser, an endorsement of the adviser, or any reference by a current client to the adviser. An endorsement is any statement by a person other than a current client or private fund investor that has the same effect. The distinction matters for what the speaker must be described as in the disclosure.

Required disclosures at the point of dissemination

For every testimonial or endorsement, the adviser must clearly and prominently disclose, in the advertisement itself, three things:

• Whether the speaker is a current client or private fund investor (testimonial), or a person other than such (endorsement).
• Whether the speaker is receiving cash or non-cash compensation from the adviser, directly or indirectly, in exchange for the statement.
• A brief statement of any material conflicts of interest on the part of the speaker resulting from the adviser's relationship with the speaker.

"Clear and prominent" is interpreted strictly. The disclosure must appear in the same medium as the statement and at the same time it is delivered. A disclosure buried in a bio link or a pinned post does not satisfy the rule.

Additional required disclosures

The adviser must also disclose, in a separate but easily accessible location, the material terms of the compensation arrangement, including a description of the compensation provided or to be provided, and a description of any material conflicts of interest on the part of the speaker. This second-tier disclosure is typically delivered through a linked landing page.

Written agreement requirement

If the adviser pays a promoter more than US$1,000 in any twelve-month period, in cash or non-cash compensation combined, the adviser must enter into a written agreement with the promoter that, at minimum, describes the scope of the agreed-upon activities and the terms of compensation.

Disqualification provisions

Rule 206(4)-1(e)(2) bars the use of a compensated testimonial or endorsement from a "disqualified person" — broadly, a person subject to certain SEC, CFTC, or state regulator orders, court injunctions, or felony or misdemeanor convictions involving false statements, fraud, or other specified misconduct. Diligence on the speaker is a programme obligation, not a one-time check.

Adviser oversight

The adviser must have a reasonable basis for believing that the testimonial or endorsement, and the required disclosures, comply with the rule. In practice this means policies, procedures, and supervisory review of compensated promoter content before publication.

The testimonial and endorsement provisions are the most operationally demanding part of the rule for any adviser that uses third-party promoters, finfluencers, or compensated reviewers. The detailed operational framework — pre-engagement diligence, written agreements, pre-publication review, disclosure verification at point of dissemination, post-publication monitoring, and retention — is covered in detail in our finfluencer compliance pillar.

Third-party ratings

Rule 206(4)-1(c) governs how an adviser may use a third-party rating in an advertisement. A "third-party rating" is a rating or ranking of an adviser provided by a person who is not a related person and who provides such ratings or rankings in the ordinary course of business.

An adviser may use a third-party rating only if both of the following apply:

• The adviser has a reasonable basis for believing that any questionnaire or survey used in the preparation of the third-party rating is structured to make it equally easy for a participant to provide favourable and unfavourable responses, and is not designed or prepared to produce any predetermined result.
• The adviser clearly and prominently discloses, in the advertisement, the date on which the rating was given and the period of time upon which the rating was based; the identity of the third party that created and tabulated the rating; and, if applicable, that cash or non-cash compensation has been provided by or on behalf of the adviser to the third party in connection with obtaining or using the rating.

In practice, common failure modes examiners catch are: omitting the rating period (advisers display "Top 100" or similar accolades without saying the period the rating covered), omitting the compensation disclosure when the rating was pay-to-play, and stating that a rating is "based on independent research" when the questionnaire structure does not support that claim. Each of these is a separate violation.

Performance advertising

Rule 206(4)-1(d) is the operationally densest part of the rule. It governs how performance information may be presented and substantially codifies the prior Clover Capital no-action framework while adding new constraints, particularly around hypothetical performance.

Gross and net performance

An advertisement may not include any presentation of gross performance unless it also presents net performance with at least equal prominence to, and in a format designed to facilitate comparison with, the gross performance. Net performance must be calculated over the same time period and using the same methodology as the gross performance.

The "equal prominence" requirement is taken literally. A footnote disclosure of net performance after a marquee gross-performance chart fails the standard. Examiners look for side-by-side gross/net presentation or equally weighted lines on a chart.

Prescribed time periods

An advertisement that presents performance of an account, portfolio, or composite must present that performance for one-, five-, and ten-year periods (or, if the relevant account, portfolio, or composite has not been in existence for ten years, since the inception of that account, portfolio, or composite). Each period must end on a date that is no less recent than the most recent calendar year-end. The standard time-period requirement does not apply to private fund advertisements.

Related performance

An advertisement that presents the performance of one or more related portfolios (those with substantially similar investment policies, objectives, and strategies to the services being offered) must include the performance of all related portfolios, with limited exclusions only where the exclusion would not result in a materially higher performance and where the related portfolios excluded share characteristics with those included.

Extracted performance

If an advertisement presents the performance of one or more investments extracted from a portfolio, the advertisement must also provide, or offer to provide promptly, the performance of the total portfolio from which the extract was taken.

Hypothetical performance

Hypothetical performance — including model performance, backtested performance, target performance, and projected performance — is subject to heightened restrictions. The adviser must:

• Adopt and implement policies and procedures reasonably designed to ensure that hypothetical performance is relevant to the likely financial situation and investment objectives of the intended audience.
• Provide sufficient information to enable the recipient to understand the criteria used and assumptions made in calculating the hypothetical performance.
• Provide, or offer to provide promptly, sufficient information to enable the recipient to understand the risks and limitations of using the hypothetical performance.

Hypothetical performance must not be distributed to a mass-market audience. It is intended for audiences that have the resources and expertise to assess it — typically institutional or sophisticated private fund investors. Distributing model or projected performance in a broad-market digital advertisement is one of the most common Marketing Rule violations cited in enforcement.

Predecessor performance

An adviser may present the performance results of a portfolio managed at a prior firm as the adviser's own performance, but only if the strict "portability" conditions are met: the person responsible for the prior performance manages accounts at the current firm; the accounts at the prior firm were sufficiently similar; all accounts at the prior firm that were managed in a substantially similar manner are advertised, unless exclusion would not raise the performance; and the advertisement clearly and prominently includes all relevant disclosures about the prior firm.

Books and records (Rule 204-2) and Form ADV updates

The Marketing Rule was paired with amendments to Rule 204-2, the books-and-records rule, that require advisers to retain extensive records of their marketing activities.

The retention period is five years from the date on which the advertisement was last disseminated, with the first two years in an easily accessible place. Records required to be retained include:

• A copy of each advertisement disseminated, directly or indirectly, by the adviser.
• Documentation of the adviser's basis for any material statement of fact that requires substantiation.
• Documentation of any third-party rating, including the questionnaire or survey used and the rating period.
• The written agreement with any compensated promoter.
• Records of the adviser's compliance reviews, approvals, and the reasoned basis for performance presentations.

Form ADV Part 1A was also amended to add new questions in Item 5.L about the adviser's marketing activities. Advisers must answer yes or no on whether their advertisements include testimonials, endorsements, third-party ratings, references to specific investment advice, performance results, hypothetical performance, or predecessor performance. The answers are public.

The Form ADV item is read by examiners as a road-map to the adviser's marketing activity. A "yes" answer to hypothetical performance, for example, signals to examiners that hypothetical performance disclosures and audience-restriction policies will be a focus of any examination. Misalignment between Form ADV answers and what the adviser actually publishes is itself a finding.

Recent enforcement: what the SEC is actually catching

Marketing Rule enforcement has built steadily since the compliance date. The pattern is consistent: examiners are catching the same kinds of failures across firms of every size.

The September 2023 sweep — hypothetical performance

On 11 September 2023, the SEC's Division of Enforcement announced settled charges against nine investment advisers — the first significant Marketing Rule sweep — for advertising hypothetical performance to the general public on their websites without adopting and implementing the policies and procedures required by Rule 206(4)-1(d)(6). The nine firms paid US$850,000 in combined civil penalties. The cases established that the hypothetical-performance audience-suitability rule has real teeth: advisers cannot put hypothetical results on a public webpage and rely on a generic disclaimer.

The April 2024 hypothetical-performance actions

On 12 April 2024, the SEC announced settled charges against five investment advisers — GeaSphere LLC, Bradesco Global Advisors Inc., Credicorp Capital Advisors LLC, InSight Securities Inc., and Monex Asset Management Inc. — for again advertising hypothetical performance to the general public on their websites without the required policies and procedures. Combined penalties were US$200,000. One of the five also had additional violations including false and misleading statements and unsubstantiated performance claims, signalling that the agency continued to focus on hypothetical performance as the principal Marketing Rule failure surface.

March 2024: AI-washing cases

The SEC charged two advisers — Delphia (USA) Inc. and Global Predictions Inc. — with making false and misleading statements about their use of artificial intelligence in their advisory services. These were the first AI-washing enforcement cases under the Marketing Rule and put advisers on notice that AI capability claims would be examined for substantiation.

The September 2024 sweep

On 9 September 2024, a second Marketing Rule sweep brought settled charges against nine advisers for unsubstantiated statements (Prohibition 2) and missing testimonial, endorsement, and third-party rating disclosures (Rule 206(4)-1(b) and (c)). Combined penalties were US$1,240,000. The most-cited statements were claims of being "conflict-free," "top-ranked," or having received "thousands of testimonials" without the underlying substantiation.

April 2024 Risk Alert (Initial Observations)

On 17 April 2024, the Division of Examinations published its "Initial Observations Regarding Advisers Act Marketing Rule Compliance" Risk Alert, flagging the deficiencies most commonly observed in the first round of post-compliance-date examinations: untrue or unsubstantiated statements, missing testimonial and endorsement disclosures, performance-presentation defects, and inconsistencies between Form ADV Section 5.L answers and the firm's actual marketing activity.

December 2025 Risk Alert (Additional Observations)

On 16 December 2025, the Division of Examinations followed up with the "Additional Observations Regarding Advisers' Compliance with the Advisers Act Marketing Rule" Risk Alert. The alert covered the same recurring deficiency patterns at greater depth, with particular attention to disclosure prominence, the use of third-party ratings, and oversight of compensated endorsements.

January 2026 FAQ update

The SEC's Division of Investment Management updated its Marketing Compliance FAQs on 15 January 2026, with clarifications on disqualification considerations for compensated endorsements, the use of model fees when presenting net performance, and the treatment of performance presented in private fund communications.

The throughline

Three years of enforcement under the new rule have surfaced a clear and consistent pattern. The disclosures-at-the-point-of-dissemination obligation is where most firms fail; the unsubstantiated-statement prohibition is where the marketing copy fails; and the performance-presentation rules are where the investment communications fail. Firms with a strong programme on those three surfaces are largely surviving exams; firms that treated the new rule as a "rebrand of the old rule" are not.

Building a Marketing Rule compliance programme

A defensible Marketing Rule programme is operational, not theoretical. It rests on five pillars.

1. A policy library mapped to the rule

Every section of the rule should be reflected in the firm's marketing policy: the seven general prohibitions, the testimonial and endorsement disclosure requirements, the third-party rating conditions, the performance-advertising standards, and the books-and-records requirements. The library is the source of truth for what review looks for, and for what evidence is captured.

2. Pre-publication review with audit trail

Every advertisement — every email, every social post, every webinar deck, every podcast asset, every paid digital placement, every RFP response, every pitch deck — must pass through pre-publication review by a person or system authorised to apply the policy library. The review must produce, for every flagged or approved item, a record of what was reviewed, what rule was applied, what the reviewer decided, and who approved.

3. Disclosure templates with version control

Required disclosures should not be redrafted for each piece of content. They should sit in a versioned template library, applied automatically to the relevant content type, and audited centrally when the firm decides to change them. A template change should propagate; a one-off variant should be flagged.

4. Books-and-records retention strategy

Every piece of content the firm publishes, plus the substantiation behind it, plus the reviewer decisions, plus the third-party agreements, plus the questionnaire data for third-party ratings — all of it must be retained for five years, with the first two in easily accessible form. This is a storage and indexing problem, and most firms underestimate it until their first exam request.

5. A Form ADV update process

Section 5.L is a live attestation. When the firm starts using testimonials, the answer changes. When it stops using hypothetical performance, the answer changes. The marketing programme must include a defined process for synchronising Form ADV with what marketing is actually doing — typically a quarterly review of the section against marketing-activity logs.

The first three pillars are where the operational workload sits. The fourth and fifth are where the audit trail lives. Firms that get the operational pillars right but skimp on retention and Form ADV synchronisation still fail exams.

How Sedric helps RIAs comply with the Marketing Rule

Sedric is the AI compliance platform that operationalises the Marketing Rule programme described above. The platform addresses Rule 206(4)-1 end-to-end: pre-publication review, disclosure verification, performance-advertising checks, books-and-records retention, and Form ADV synchronisation.

A Marketing Rule-aware policy library. Sedric ships with a policy library mapped to every section of Rule 206(4)-1 — the seven general prohibitions, the testimonial and endorsement disclosure requirements, the third-party rating conditions, the performance-advertising standards. The library is configurable so the firm can layer its own product-specific and audience-specific overlays on top.

Pre-publication review across every channel. Every advertisement — website, social, paid digital, video, podcast, email, RFP response, pitch deck, investor letter — is reviewed in real time as the marketer or adviser creates it. Flags link to the underlying rule citation in one click. Reviewers and principals receive flagged items routed to their queue.

Standalone-asset disclosure verification. The platform assesses each individual asset on its own for required testimonial and endorsement disclosures, performance-presentation completeness, and third-party rating attribution — the way examiners actually look at content.

Performance-advertising checks. Gross-only performance is flagged before publication. Cherry-picked time periods are flagged against the 1-/5-/10-year standard. Hypothetical performance is flagged against audience suitability — mass-market distribution is blocked unless the policy library specifically permits it for the recipient class.

Decision logging and books-and-records retention. Every review decision is timestamped, attributable, and exportable to a five-year retention store with the first two years in immediately accessible form. The export is what an examiner asks for, not what the marketing team thought to retain.

Form ADV synchronisation. Marketing-activity logs are aggregated against the Section 5.L attestation: when activities start or stop, the policy committee is notified ahead of the next ADV amendment cycle.

The same platform extends to communications surveillance under Rule 17a-4 and 204-2, marketing review of finfluencer content, and the wider marketing compliance programme. Many of our RIA and dual-registrant clients run the Marketing Rule, eComms surveillance, and partner-content review on a single Sedric instance with a single audit trail.

Frequently asked questions

Does the SEC Marketing Rule apply to private fund advisers?

Yes. The rule applies to SEC-registered investment advisers, regardless of whether they manage separately managed accounts, private funds, or both. Private fund communications are subject to all the general prohibitions and the testimonial and endorsement provisions. The prescribed 1-/5-/10-year time-period requirement does not apply to private fund advertisements, but the gross-net presentation requirement does.

Does the rule apply to state-registered investment advisers?

The federal Marketing Rule applies to SEC-registered advisers. State-registered advisers are subject to the analogous rules of their state regulator. Most state regimes substantially track the federal rule, but specific requirements vary by state, and dual-registered firms must comply with both.

Do broker-dealers have to comply with the Marketing Rule?

Broker-dealers are subject to FINRA Rule 2210 for communications with the public. The substantive standards overlap considerably with the SEC Marketing Rule but the technical requirements differ. Dual-registrants — firms registered as both advisers and broker-dealers — must comply with both rules, and the higher standard generally governs each piece of content.

Are oral, extemporaneous communications covered by the rule?

Live, extemporaneous oral communications are excluded from the definition of "advertisement." Pre-recorded content (video, podcasts, webinars), even where it is conversational in tone, is not extemporaneous and is therefore an advertisement.

What is "clear and prominent" disclosure?

The required testimonial, endorsement, and third-party rating disclosures must appear in the same medium as the statement, at the same time as the statement, and in a manner the audience cannot reasonably miss. A footnote in small grey type, a disclosure on a separate page reached only by following a link, or a disclosure in a profile bio rather than in each individual post does not satisfy the standard.

How long do we have to keep marketing materials?

Five years from the date the advertisement was last disseminated, with the first two years in an easily accessible place. The retention obligation extends to the substantiation behind material statements, third-party rating questionnaires, written agreements with promoters, and reviewer decisions.

What is hypothetical performance, and why is it restricted?

Hypothetical performance includes model performance, backtested performance, target performance, and projected performance — anything that is not the actual realised performance of an account, portfolio, or composite. The rule restricts hypothetical performance because it can be more easily manipulated and is more difficult for retail audiences to assess. It generally cannot be distributed in mass-market advertising and is intended for audiences with the resources and expertise to assess it.

Do we need a written agreement with every finfluencer?

If compensation, cash or non-cash combined, exceeds US$1,000 in any twelve-month period, a written agreement is required. Below that threshold, an agreement is not technically required, but most firms put one in place for every compensated promoter as a matter of policy because the threshold can be crossed without the firm noticing.

How are AI-related claims treated under the rule?

AI-related claims about an adviser's services are statements of material fact that must be substantiated. The March 2024 enforcement actions against Delphia (USA) Inc. and Global Predictions Inc. established that AI capability claims will be scrutinised under the rule's substantiation and untrue-statement prohibitions. If the firm says it "uses AI for asset selection," it must be able to demonstrate, on demand, that AI is actually material to the asset-selection process.

Is the Form ADV Section 5.L answer something the SEC actually looks at?

Yes. Examiners read Section 5.L as a road-map to the firm's marketing activity. Misalignment between the firm's Section 5.L answers and what the firm actually publishes is itself a violation and frequently a precursor to deeper inquiry into the marketing programme.

What happens if we discover an old advertisement that doesn't comply?

The compliance date was 4 November 2022. Any advertisement disseminated after that date should comply with the rule, regardless of when the creative was first produced. Discovery of a non-compliant advertisement should trigger immediate removal or correction, a record of the remediation, and consideration of self-reporting depending on the materiality and the regulator's published expectations.

Can we use a single global disclosure for our website rather than per-asset disclosures?

Not for testimonials, endorsements, or third-party ratings. The disclosure must appear in the same medium and at the same time as the statement. A global disclosure at the bottom of the website does not cover a testimonial that appears on a different page or in a social post. Each asset must carry its own disclosure.

Ready to build a defensible Marketing Rule programme?

Sedric is the AI compliance platform purpose-built for the SEC Marketing Rule and the broader RIA and wealth-management compliance stack. Our platform reviews every advertisement against Rule 206(4)-1 before it ships, captures the audit trail an examiner expects, and operates inside the workflows your marketers and advisers already use.

Book a working session with our team to walk through the rule on your actual content: your website, social, paid digital, performance presentations, and any compensated promoter or third-party rating arrangements. You will see real flags on real assets, with citations to the specific rule prohibition or condition, and the audit export you would hand to an SEC examiner.

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Related reading

• Influencer and finfluencer compliance for regulated firms — the operational framework for compensated promoter arrangements under the Marketing Rule.
• Marketing compliance: the complete 2026 guide for regulated firms — the cross-regulator pillar covering SEC, FINRA, FCA, MiCA, ASIC.
• AI compliance software for financial services: the 2026 buyer's category page.