Dear Friends,
On March 31, 2014, the SEC issued Guidance regarding Rule 206(4)-1(a)(1) of the Investment Advisers Act (“the testimonial rule”) and social media.
The SEC generally prohibits client testimonials. However in its guidance, the SEC said client testimonials on independent social media sites are permissible, in certain circumstances, with the following important considerations:
An investment adviser (“IA”) or investment advisory representative (“IAR”) may publish all unedited testimoni...
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