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Testimonials and endorsements checklist

Use this before a client quote, review or paid referral appears anywhere you advertise. It follows 17 CFR 275.206(4)-1(b).

Before it goes live

1. Say who is speaking. Clearly and prominently state whether the person is a current client (a testimonial) or not a current client (an endorsement).
2. Say if they were paid. If cash or non-cash compensation was given for it, say so.
3. Disclose conflicts. Briefly state any material conflict the person has because of their relationship with you.
4. Describe the compensation terms. Give the material terms of any compensation arrangement.
5. Have a reasonable basis to believe the testimonial or endorsement complies with the rule.
6. Sign a written agreement with anyone you pay, covering the scope of the work and the compensation.
7. Screen for disqualification. Do not pay anyone you know, or with reasonable care should know, is an ineligible person (the rule defines disqualifying events and Commission actions).

Exemptions to check

• No or minimal pay. Unpaid, or de minimis pay of $1,000 or less in the past 12 months, is exempt from the written agreement and the disqualification check.
• Your own people. Statements by your partners, officers, directors or employees (and affiliates) are exempt from the disclosure and agreement conditions, if the tie is obvious or disclosed and you document their status.
• Registered broker-dealers and certain private-offering participants have their own carve-outs.

What to keep

A list of every testimonial and endorsement, who gave it, whether and how they were paid, the written agreement, the disclosures as shown, and proof you checked eligibility.

Scan your website for testimonials

Source: 17 CFR 275.206(4)-1, read 2026-10-16. Not legal advice.