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Hazelsong

For financial advisers

The SEC Marketing Rule, Rule 206(4)-1

Client endorsements, under the rule that finally allows them

Until November 2022 an investment adviser could not publish a client testimonial at all. The Marketing Rule changed that — and it did not simply permit them: it attached conditions to every one, and those conditions are about the record behind the words rather than the words themselves.

  • Every testimonial read for the claims your rule cares about, before it is public
  • The client's permission recorded in writing, and enforced everywhere this product shows it
  • A private detail removed with [removed] — never a word reworded

Create your Wall of Love

$29 a month for unlimited testimonials, or the limited tier, which holds 15 and needs no card.

Shown to your customers on the page that asks them.

The address you log in with, and where replies to your requests arrive. Never sold.

No password: your dashboard opens from a private link the moment the project is made.

In our words

The rule you are working under

What the rule requires, in our words

An adviser may use a testimonial or an endorsement, provided the advertisement is not presented in a manner that is unfair or unbalanced, and provided it discloses clearly and prominently whether the person is a client, whether they were compensated, and any material conflict of interest.

A summary of The SEC Marketing Rule, Rule 206(4)-1, written by Hazelsong — not a quotation from it. Read The Division of Investment Management's Marketing Rule FAQ, sec.gov.

The rule became effective on 4 May 2021 and compliance was required from 4 November 2022; an adviser could adopt it early, but not partially. Two of its conditions land on how a testimonial is collected rather than on how it reads: a presentation that is not fair and balanced is prohibited, and compensation given for an endorsement has to be disclosed. A written agreement is required with a promoter paid more than $1,000 in twelve months.

Hazelsong does not interpret this rule and does not make anyone compliant with it. It gives you the record and the controls; the judgment stays yours.

What it does

What Hazelsong does about it

01

It will not help you publish only the favorable half

The 0-to-10 question is sold elsewhere with routing attached: the high answers to a public review, the rest to a private form. A set of endorsements assembled that way is the opposite of fair and balanced. Here the score changes the wording of the question and nothing else, everybody is offered the same place to write, and your own figure counts every answer rather than the ones that were published.

02

Anything given for an endorsement is disclosed, permanently

If a reward was attached to writing — before or after the words — every published copy says so, with what it was. There is no field anywhere that turns it back off, which is the difference between a disclosure and a setting.

03

The permission is a sentence with a date, not a checkbox

The client reads exactly what they are agreeing to and marks where it may appear. That sentence, those places and the date are stored with the words and travel in your export, which is what you hand over when somebody asks how the endorsement was obtained.

04

A reader can check the record themselves

Every published testimonial links to its own record, on our address rather than yours: how it arrived, which permission was given and by whom, whether it was read before publication, whether a part was removed, whether anything was given for it. Nothing on that page can be styled, bought or switched off.

05

It marks the sentence your advertising should not carry

A predicted return, a figure, a claim of expertise: flagged with the reason on arrival, sitting in Pending until you decide, and never published automatically.

What it gives you is the half of the rule that is about the record: written permission with its date, anything given disclosed on every copy, every testimonial read before it was public, and a page a regulator or a client can open to see how each one was obtained.

Before anything is public

Read for what your rule cares about

A promised result, a figure, a claim of specialization, a client's private detail — each is marked with the words that triggered it and one plain sentence of why, and nothing is published until you approve it.

How the reading works
Your dashboard · Pending
Customer name

Every word arrives as they wrote it — even the 555-0142 they meant to leave out.

Read this before publishing"555-0142" A phone number. Take it out before this goes on your site.Read automatically when it arrived. It points; you decide.
A version with parts removed is readyEvery word arrives as they wrote it — even the [removed] they meant to leave out.
ApproveRejectPublish this version instead
Drawn from the product's own markup and labels, with example words — not a real customer.

Limits, stated

What it does not do

  • Hazelsong does not write your disclosures and does not place them for you. Whether a person is a client, and any material conflict of interest, are facts about your relationship that this product does not know — the line beneath your wall is yours to write.
  • Hazelsong does not hold promoter agreements and is not a books-and-records system for Rule 204-2.
  • Hazelsong does not make you compliant with the Marketing Rule and does not audit you. Nothing here is legal or compliance advice.

Your clients already wrote the words

Send one link and their words arrive here instead — with the date, with the permission, and read for risk before you publish.