For RIAs & compliance officers

Every testimonial andpaid promoter, graded.

The Marketing Rule lets you use testimonials, endorsements, and paid promoters — under conditions firms miss constantly. A paid-lead service is a promoter. A revenue-share solicitor is a promoter. This grades every arrangement on the rule's conditions and flags the ones that can't run yet, before an examiner finds them.

Get the Audit — $79one-time · instant download · yours to keep

Not legal advice. A deterministic readiness aid that grades an arrangement from your own marks — it renders no legal ruling, confirms no compliance status, and scores no person. SEC Marketing Rule 206(4)-1 has conditions and exceptions this tool simplifies for triage; confirm every requirement, including the de-minimis calculation and exact disclosure language, with your compliance counsel before you advertise.

Five deliverables · runnable
Compliance Scorecard workbook
xlsx
Marketing-Rule Audit Playbook
docx
Remediation Runbook
docx
Runnable Python engine
py
Six-arrangement worked sample
csv
Works alongside
AI Reputation & Reviews Engine · Web-Form Consent Gate · UGC Ad Compliance System
01.The Problem

The arrangements that trip the Marketing Rule rarely look like testimonials.

Paid leads = promoters

A service paid to send you prospects, with a match that implies an endorsement, is a compensated promoter arrangement — the most-overlooked one in the rule.

The written agreement

A compensated, over-de-minimis promoter needs a written agreement on file. Its absence is the single most common Marketing-Rule exam finding.

Standing exam priority

Marketing-Rule compliance has been a recurring SEC examination focus, with disclosure and substantiation among the areas staff flag most.

Two conditions decide most arrangements: is the required disclosure clear and prominent, and — for a paid promoter — is there a written agreement on file. The Audit grades those two plus four more, and it knows the written agreement is only required when the promoter is actually compensated.

02.See It Work

Set each arrangement's type. The gate fires only where the rule actually requires it.

Live demo · campaign readiness

Set each arrangement's type, then mark 0 / 1 / 2. The type drives the written-agreement gate. As of 2026-07-05.

Campaign verdict
PULL OR FIX
2
non-compliant

Gate fired — SmartAsset paid referral (compensated) scores 80 (COMPLIANT on points alone) but reads NON-COMPLIANT because written agmt is absent. A strong asset can't rescue a missing statutory requirement.

ArrangementTypeDisclosurefatalWritten agmtfatal if paidComp/conflictsNot disq.SubstantiatedRetainedScoreVerdict
80NON-COMPLIANT
84COMPLIANT
80COMPLIANT
76COMPLIANT
58NON-COMPLIANT
100COMPLIANT

Fix first: NAPFA advisor spotlight — the worst arrangement in the set.

Grades the arrangement, never a person. It renders no legal ruling and confirms no compliance status. Not legal advice — the Marketing Rule has conditions and exceptions this tool simplifies; confirm every requirement with compliance counsel before you advertise.

03.What's Inside

A workbook for the CCO, and an engine that grades your whole marketing inventory from a CSV.

The same logic runs three ways — a zero-dependency Python engine, an Excel workbook that reproduces it exactly, and the live demo above. Verbatim output on the shipped six-arrangement sample:

============================================================================
  MARKETING-RULE TESTIMONIAL & PROMOTER AUDIT
  Campaign readiness read - as of 2026-07-05
============================================================================

  CAMPAIGN VERDICT ...... PULL OR FIX
  Arrangements graded ... 6
  Non-compliant ......... 2 of 6  (33% exposed)

----------------------------------------------------------------------------
  ARRANGEMENT                   TYPE          SCORE  VERDICT        NOTE
----------------------------------------------------------------------------
  SmartAsset paid referral      compensated      80  NON-COMPLIANT  gate: written_agreement
  Google 5-star reviews embed   uncompensated    84  COMPLIANT      
  Client video testimonial      de_minimis       80  COMPLIANT      
  Solicitor RIA (revenue share) compensated      76  COMPLIANT      
  NAPFA advisor spotlight       uncompensated    58  NON-COMPLIANT  gate: disclosure
  Employee LinkedIn endorsement affiliate       100  COMPLIANT      
----------------------------------------------------------------------------
  4 compliant  -  0 gaps  -  2 non-compliant

  ! GATE FIRED: SmartAsset paid referral
    Scores 80 (COMPLIANT on points alone) but reads NON-COMPLIANT
    because Written promoter agreement on file is absent.
    A strong asset can't rescue a missing statutory requirement.

  ! GATE FIRED: NAPFA advisor spotlight
    Scores 58 (GAPS on points alone) but reads NON-COMPLIANT
    because Required disclosures clear & prominent is absent.
    A strong asset can't rescue a missing statutory requirement.

  FIX FIRST: NAPFA advisor spotlight
    Required disclosures clear & prominent

  Grades the arrangement, never a person. Renders no legal ruling and
  confirms no compliance status. Not legal advice - confirm every
  requirement with compliance counsel before you advertise.
============================================================================

Note the honest edge case: the SmartAsset referral and the client video both score 80. The paid referral reads NON-COMPLIANT because a compensated promoter needs a written agreement; the de-minimis video stays COMPLIANT. Same marks, different verdict — because the rule treats them differently, and so does the gate.

04.The Standard

Three rules that make the verdict trustworthy.

The gate follows the rule

A missing disclosure trips every arrangement. A missing written agreement trips only a compensated one — because that's the only place the rule requires it. The gate doesn't over-fire.

It grades the arrangement, not the law

It renders no legal ruling and confirms no compliance status. The Marketing Rule's conditions and exceptions run deeper than any six-control model — this readies you to have the conversation, not to skip it.

The worst asset sets the campaign

One NON-COMPLIANT arrangement makes the campaign PULL OR FIX. A single unpapered paid-lead deal is enough — which is why the inventory comes first.

05.What It Is — And Isn't

A readiness aid that grades your testimonial and promoter arrangements from your own marks.

It is
  • A deterministic, offline read of each testimonial, endorsement, and promoter arrangement.
  • A per-arrangement COMPLIANT / GAPS / NON-COMPLIANT verdict with a conditional written-agreement gate.
  • A ranked remediation plan — clear the fatal gaps, then close the rest in weight order.
  • A workbook for the CCO plus an engine that grades a large inventory from a CSV.
It isn't
  • ✕A legal ruling or a confirmation of any compliance status.
  • ✕A compliance certification, safe harbor, or opinion of counsel.
  • ✕A drafter of agreements or disclosure language — it flags what's missing, not the words to add.
  • ✕A reader of your ads, and it scores no person; the de-minimis calculation stays yours to confirm.

Not legal advice. A deterministic readiness aid that grades an arrangement from your own marks — it renders no legal ruling, confirms no compliance status, and scores no person. SEC Marketing Rule 206(4)-1 has conditions and exceptions this tool simplifies for triage; confirm every requirement, including the de-minimis calculation and exact disclosure language, with your compliance counsel before you advertise.

06.Who It's For

The person who signs off before a testimonial or a paid-lead deal goes live.

Chief Compliance Officers

Inventory every testimonial, endorsement, and paid-lead relationship on one standard, and know which ones can't run until the disclosure or the agreement is fixed.

Solo & small RIAs without a CCO

Same rule, no compliance team. Grade your reviews, referrals, and solicitor deals yourself, and see the fatal gaps before the exam does.

Marketing leads at advisory firms

Before you embed a review wall or sign a lead-gen contract, check it against the rule's conditions so the campaign is defensible from day one.

Compliance consultants

A repeatable per-arrangement scorecard to run across client firms, with a ranked remediation list you can hand back.

07.Pairs Well With

Cover the rest of your marketing-compliance surface.

AI Reputation & Reviews Engine

Earn and respond to reviews on the right side of the FTC Consumer Review Rule — the review-side companion to this audit.

View

Web-Form Consent & Lead-Capture Gate

The other RIA-adjacent gate: TCPA consent readiness for the lead-capture forms that feed your funnel.

View

AI UGC Ad Compliance System

Check AI and UGC-style ads before they run — the claim-and-persona linter that hard-blocks a fake testimonial.

View
08.Common Questions

The answers a CCO asks for first.

Yes — and it's the most-missed arrangement in the whole rule. When you pay a service to send you prospects and its match or listing implies an endorsement of your firm, that's a compensated promoter arrangement under Rule 206(4)-1, subject to the disclosure and written-agreement conditions. It doesn't feel like a 'testimonial,' which is exactly why firms overlook it. Mark every paid-lead vendor as a 'compensated' arrangement and the audit will check it for the written agreement and disclosures the rule requires.

Grade the arrangement
before the examiner does.

One purchase, lifetime access, 12 months of updates. $79, once.

Get the Audit — $79

Not legal advice. A deterministic readiness aid that grades an arrangement from your own marks — it renders no legal ruling, confirms no compliance status, and scores no person. SEC Marketing Rule 206(4)-1 has conditions and exceptions this tool simplifies for triage; confirm every requirement, including the de-minimis calculation and exact disclosure language, with your compliance counsel before you advertise.

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