Testimonials

I have been seeing a lot of LinkedIn endorsements of late.  An “endorsement”, similar to a “recommendation” is considered a testimonial.  The SEC Advertising Rule prohibits an investment adviser from using any advertisement that refers to any testimonial concerning the investment adviser or any advice, analysis, report, or other service rendered by the investment adviser.

Therefore, it is recommended that you say “no” to any endorsements or recommendations on LinkedIn.

Also, now would be a good time to update your Compliance Manual to include these prohibitions.

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2 Responses to Testimonials

  1. Alan Moore says:

    Interestingly enough, the Wisconsin Regulators just sent a newsletter with the following statement: “A more recent LinkedIn development concerns the ability of others to “endorse” any skills that you have listed on your profile. If you have skills listed, an endorsement can appear without first giving you the ability to accept or decline the endorsement for posting. At this stage, it appears that the only way to avoid an endorsement is not to have any skills listed. However, a LinkedIn endorsement does not include any narrative comments, and we have not yet seen any regulatory opinions that would equate an endorsement with a testimonial. (Note that the Edit Profile function can be used to hide endorsements, but that hiding an endorsement has the effect of permanently deleting it.)”

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