RedHub AI
How the gate works
How the Marketing-Rule Testimonial & Promoter Audit works
This tool grades each testimonial, endorsement, and paid-promoter arrangement under SEC Marketing Rule 206(4)-1 on six controls, with a conditional gate. It scores 6 weighted controls into a 0–100 number — then a gate that can only make the verdict worse.
The 6 weighted controls
Two controls are dispositive, and the gate follows the rule. A missing required disclosure trips every arrangement. A missing written promoter agreement trips only a compensated one — because that is the only place the Marketing Rule requires it. When a dispositive control is absent the arrangement is NON-COMPLIANT regardless of the score; the gate worsens only, and never over-fires.
Why: This SmartAsset paid referral is otherwise clean — disclosure clear, compensation disclosed, promoter not disqualified, claims substantiated, ad copy retained — for a score of 80 that on points alone reads COMPLIANT. But it is a compensated promoter with no written agreement on file, the one control the Marketing Rule makes mandatory for a paid promoter. The gate fires, because a strong asset can't rescue a missing statutory requirement, so it reads NON-COMPLIANT, not COMPLIANT. The same 80 on a de-minimis arrangement would stay COMPLIANT — the rule treats them differently, and so does the gate.
A high score didn’t save it. The score is context; the gate is the answer — and it names the one thing to fix first. 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.