Financial Advisors: Making Sense of the SEC’s Third-Party Review Site Rules


This post was authored by Marie Swift and originally appeared here on GuideVine.

Financial Advisors and the marketing consultants who specialize in working with them know that the SEC no-testimonials rule prohibits Registered Investment Advisers and Investment Adviser Representatives from using client endorsements in their advertising. But in April 2014, the SEC issued new guidelines on the use of social media and online communications, which opened the door to something new: the ability for Advisors share on their own websites and profile pages public comments about their services that are posted on independent websites (such as Yelp, Angie’s List, Wallet Hub, and GuideVine).

There are, of course, rules related to how the content from these third-party sites can be used on sites and profile pages the Advisory firm controls. Here’s how to think things through.


The Advisor must include both positive and negative reviews. This means there can be no cherry picking — the Advisor must publish all comments, unedited. Financial Advisors can’t just copy and paste the good ones and leave the bad ones behind on the third-party site.

The SEC guidance specifically says: “The investment Adviser may publish only the totality of the testimonials from an independent social-media site and may not highlight or give prominence to a subset of the testimonials.”

Advisors can also publish mathematical averages of the comments from third-party review sites.

The best way to benefit from the third-party review sites, according to many industry consultants, is to post the logo and a link to the page where the third-party reviews live.

In this writer’s opinion, it could be worth linking to the third-party review page and monitoring daily to ensure that one is comfortable with any new comments. If the comments on the third-party review site ever become a concern, Advisors have a couple choices — remove the logo and link to the third-party site or embrace the fact that studies show that companies that have a disproportionate number of marginal or negative reviews are seen as more credible and real.


Stats from social commerce company Reevoo show that, while it may seem counterintuitive, the presence of a few bad reviews is actually a good thing.

“Reevoo found that people that seek out and read bad reviews convert better, as the very fact that they are paying such close attention means they are more likely to be in purchase mode,” says writer Vikki Chowney in an article on “68% of consumers trust reviews more when they see both good and bad scores, while 30% suspect censorship or faked reviews when they don’t see any negative opinions on the page.”

The Edelman Trust Barometer shows that people now trust one another more than they do established institutions. People have always turned to their peers when making important decisions. Now, with social media’s impact on online search, it is easier than ever for those doing research online to find “a person like me” or “ a regular employee” — both of which are seen as more credible than a company executive or paid spokesperson.

For more insights on building trust online read this Marie Swift piece on Why Financial Advisors Can’t Ignore Social Media.


The SEC guidelines also state that Financial Advisors must not have the ability to influence comments from the general public on the third-party site. This means the Advisor must not try to influence how they’re portrayed on those third-party sites. The SEC is trying to ensure that potential clients get the full picture of an Advisory firm.

“Advisers would violate the SEC’s testimonial rule if they drafted or submitted comments to a third-party review site, paid others to submit favorable comments to the site or suppressed, edited or manipulated the order in which the commentary was presented,” said tenured industry writer Mark Schoeff, Jr. in this article published by Investment News, SEC Oks Use of Third Party Social Media Endorsements.


Beyond just the “all or nothing” restriction covered in the “no cherry picking” section of this article, Registered Investment Advisers must keep in mind that they may only publish testimonials from an independent review website in a “content-neutral manner.” According to the SEC guidelines, this means chronological or alphabetical order. It is not okay to put the best rankings at the top and the worst rankings at the bottom.

This is one reason why this writer believes it is best to simply link to the third-party review site and then monitor the discussion threads on a daily basis.


What would you do if you saw this post on a third-party review site?

“Found Jake Advisor to be out of touch, unresponsive and arrogant.”

How about this one?

“I have known John Planner for many years. One of the nicest guys you will ever meet! He knows his business and will take GREAT care of you and your assets.”

 It is human nature to want to applaud the person posting the positive comment — but Financial Advisors should refrain from doing anything that might be construed as encouraging positive comments. So the best thing to do when a Financial Advisor sees a positive comment is to do nothing — at least not publically. It would be nice however to say, “thanks for your kind comments on xyz review site,” over a cup of coffee, while at the same time explaining why you can’t try to encourage positive endorsements online.

In the case of the negative comment above, it is human nature to want to defend oneself. As a marketing communications and reputation expert, this writer believes that it would be best if the Advisor in question posted something simple such as, “I’m sorry you feel that way. Please call me to discuss.”, if the third-party site allows responses. And leave it at that. Check with compliance first, of course, to make sure their interpretation of the SEC guidelines is in alignment with this reputational recommendation.


“This rule would appear to put Advisers in the clear regarding third-party review sites, such as Yelp, presuming that the Adviser really does not have any affiliation to the site, and cannot control the comments posted (e.g., by trying to delete negative comments while allowing positive ones to remain),” said Michael Kitces, director of research at Pinnacle Advisory Group, on his blog, Nerd’s Eye View.

Check with your company’s compliance department to learn more about internal policies and procedures and/or outside legal counsel to make sure all regulatory guidelines are being met at your firm. A recent report from McGladrey, LLC, a leading provider of assurance, tax and consulting services in the US, says that financial firms should be prepared for Heightened SEC Regulatory Focus. Smart Financial Advisors will be ready for questions and conducting themselves in close alignment to the SEC rules.

Advisors: A Guide to SEO Keyword Research [Infographic]

While Google keeps us on our toes with constant Google algorithm changes and updates, one thing that remains consistent when developing a website, or creating content for a website is keyword research. Keyword research refers to the process of determining what keywords your potential customers use in search engines when searching for information. Keyword research is quite possibly the most important part of Search Engine Optimization (SEO) since you cannot begin to plan for the content on your website unless you know which words and phrases you are targeting.

Some 91% of online adults use search engines to find information on the web. And, among search users, 91% always or most of the time find the information they are looking for (Marketing Profs, 2013). They do this by typing in a keyword or keyword phrase.  In return, a search engine’s complex set of algorithms sifts through the enormous amount of webpages in order to find the most relevant pages. This is why keyword research is so important.  Keywords are used in the process of matching your website content to what your targeted viewers are looking for.  For SEO, keywords are the connector, the relationship between you and your prospects, established and indexed by the search engine.

If you want your Financial Advisory practice to be successful in online marketing, SEO remains one of the single most important component’s of any organization’s branding efforts and online presence. When developing your strategy, however, it is important to keep in mind that search engine optimization is a process that takes time to come into effect. Check out the Infographic below, courtesy of ClearSkySEO, which is a quick guide to Search Engine Optimization and keyword research.




4 Signs It’s Time to Update Your Web Site Photos

This post was authored by Kristen Harad and originally appeared here on GuideVine.


Many Financial Advisors struggle to differentiate their firms and stand out in the crowd. Often times, this is best illustrated through your Web site. If you notice any of these four signs, it may be time to get an imagery makeover.

4 Signs You Need to Update Your Web site’s Photography:

1. Your home page’s first picture is a happy silver-haired couple gazing wistfully at the horizon dreaming of their retirement.

2. You see the same image on five other Financial Advisors’ home pages, all within your city limits.

3. Your primary audience is growing families and you still show active seniors, golf courses, or Adirondack chairs on the beach.

4. You don’t actually have any images on your site.

Inspirational images like sweeping scenery and active seniors help to convey the lifestyle that 80-90 percent of the population would probably like to eventually achieve, but do these types of photos help you speak to your ideal client?

Advisors use this type of generic imagery for two main reasons: (1) they want to be sure they do not exclude any potential prospects and (2) they are the default images set from their web provider.   Based on the presumption that most people’s financial goal is to retire to a life of financial comfort, the ‘silver fox’ or tropical vacation photos convey that this is what the Advisor can help clients achieve.  Whether or not your audience is 25, 45, or 65, everyone ultimately wants the same thing.

Unfortunately, this is not only the most widely deployed marketing strategy but also one of the least effective. By casting such a wide and inclusive net, this style of communication puts the burden on potential clients to figure out whom you best serve and if you are the right professional to help them with their unique challenges. Retirement planning is of course one part of the financial planning equation, but for many clients it’s not the reason they are seeking a planner’s help.  They have many bridges to cross before that stage of life.

How important is photography?

Expert marketers care about the images they use because images draw people in. With the right photos, you can increase the probability that you will attract the right people for your practice.

When I worked at a large New York Ad agency, we spent countless hours assessing each detail of every photograph we would use in an ad or a direct mail piece, just to be certain it resonated with the client’s target audience.  How much grey hair should he have? How many wrinkles? What ethnicity? What clothes would he wear? What’s happening in the background? Is that a place he would be? What expression fits the brand? Are they too ‘happy’? Are they believable? If we had a photo shoot, where we crafted the image – then 100 times as much detail, and even more patience, came into play.

Where to Find Inexpensive, Quality Photos

The good news is that while ad agencies can spend thousands of dollars to get one photo “right,” the Web offers a proliferation of quality photos at reasonable prices.

  • Istockphoto – Select your price range from $ up to $$$$ and sizes from Small to XL. With credits you purchase, you’ll access one of the widest ranges of quality photos offered online.
  • Bigstockphoto – You can subscribe to receive a flat number of photos per month (good for a frequent blogger) or buy photos as needed. This service offers modern, intriguing photos to brighten up your site.
  • Unsplash – this unique site offers free images, no strings attached. You pick from what is posted, and you can use it any way you like. They post 10 new photos every days. You never know what you’re going to find, but you’ll certainly stand out from the crowd.

Remember, while many clients do aspire to spend their retirement observing awe-inspiring sunsets around the globe, that may not be the driving factor that leads them to hire you.  Show your clients that you understand who they are and what they want. And, please, find photos that match.

Financial Advisor Checklist: 10 Things Every Advisor Should Be Doing Online

  1. Mobile Optimized Website.

Digital traffic on smartphones and tablets has now exceeded desktops. Consumers expect a consistent experience no matter what device they are using. If your website is not mobile friendly, you are likely losing business to a website that is.

  1. A clearly defined value proposition and target audience.

Your prospects should have no difficulty understanding what it is that you do and how they can benefit from working with you. Your value proposition should contain one or more of the key benefits that you provide to your clients.

  1. Social Media Presence.

If you’re active on Twitter and Facebook, you should ensure your newsfeed is also visible on your website. Many investors use Social Media as key sources of information to help them better understand investment strategy and advice. In fact, nearly 70% of wealthy investors have reallocated investments, or began altering or already altered relationships with investment providers based on content found through social media.

  1. Engaging Imagery.

Do the images on your current site resonate with your target audience?  Are your images dated? Good quality? Legal? Unique? Relevant? Engaging? Powerful? Emotional? Are your competitors using the same image? Will your audience relate to the image?

  1. Dynamic Website.

Static sites do not perform well with your audience nor do they appear at the top of search results.  It is important to stay on top of updating your site regularly with new topics of interests, blogs, articles, etc. in order to keep search engines happy, and to keep your prospects coming back for more.

  1. Polls, Events & Community Outreach.

Are you regularly posting polls to your site to allow for audience feedback and engagement? Are you posting forms to allow your prospects and customers to RSVP to upcoming Webinars or events?

  1. Forms & Calls to Action.

What methods do you have in place to capture the information of prospects visiting your site and to convert them into leads/customers?  If the goal of your website is to create sales and get more business, then it is important that your website has effective Call to Actions. Present your value and use calls to action to direct visitors to a contact form, a newsletter subscription, or other call to actions such as webinars or a consultation.

  1. Blogging.

Hubspot reports that small businesses that blog get 55% more website visitors, and 126% higher lead growth than non-blogging businesses. Blogging also helps you to connect and engage with your prospects. It can help you establish yourself as an expert in the industry by helping to solve prospects challenges through content.

  1. Search Engine Optimization.

Are you putting time into the SEO of your website? It is important to constantly keep SEO in mind when creating and updating your website. Why build a website that no one can find? Target keywords that your target audience might search and create new content that targets these keywords. Make sure you are creating META tags for each page of your site. Meta tags are a great way for you to tell search engines what your website is all about.

      10.  eNewsletter

Do you have a method of staying “top of mind” with your prospects and clients? E-mail marketing is one of the most effective ways to stay in touch with your clients and nurture your prospects. E-Newsletters can be one of the easiest ways that Advisors can repurpose their existing content in order to engage their audience, and remain front and centre when prospects are ready to make a buying decision.


Guide to Content Marketing

The Evolving Role of the Wealth Manager [Infographic]

According to this year’s World Wealth Report, released by Capgemini and RBC Wealth Manager, wealth managers and firms are facing a crossroads between adapting to technological change or sticking to the traditional way, forcing them to decide whether they are going to respond or get left behind. These industry changes and challenges present a significant challenge as well as opportunity for wealth managers. In this series of articles, we will take a look at some of the key takeaways, from the World Wealth Report, as it relates to wealth managers and how they can meet the challenges of the rise in technology and the needs of today’s digitally focused clients.

Firms and wealth managers face a host of industry challenges which are driving the evolution of the wealth manager’s role.  The Infographic below, courtesy of Capgemini and RBC Wealth Management, explores the changing role of the wealth managers within the evolving landscape and rise of new technologies.

The Evolving Role of the Wealth Manager [Infographic]