What the rule requires

Under the SEC Marketing Rule, testimonials and endorsements on an adviser's website are allowed only with specific disclosures and oversight. Each one must say clearly and prominently whether the person is a current client, whether they were paid, and any material conflicts of interest (eCFR; SEC compliance guide). Paid promoters generally need a written agreement. The exception is de minimis compensation of $1,000 or less over 12 months.

Where websites go wrong

Design matters here. In a December 2025 risk alert, SEC staff flagged disclosures hidden behind hyperlinks or set in smaller type, and flagged reviews pulled in from third-party sites without saying whether the reviewer was a client (SEC risk alert; summary). So an embedded Google-review widget with a footnote at the bottom of the page is risky. Put the disclosure next to each quote, at the same visual weight.

How FinArt Studio handles it

When FinArt Studio designs a reviews section, the disclosures are built into each card, and the copy goes to your CCO before launch. Your compliance team makes the final call.

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