Understanding the New Investment Adviser Marketing Rule: Compliance Strategies for 2025

With the new investment adviser marketing rule set to take effect in 2025, registered investment advisers must prepare. The updated rule significantly expands the definition of marketing and brings stricter regulation around testimonials, performance presentations, and third-party ratings. Firms that proactively adapt will navigate the transition smoothly—while mitigating risks in their advertising programs.

Overview of the SEC Marketing Rule (2025)

The SEC’s update introduces sweeping changes to advertising regulations for RIAs. Under the new framework, posts on social media and webinars are now considered to be marketing. Testimonials and endorsements are heavily restricted, and performance results must follow standardized calculations. This reform aligns marketing oversight with evolving client behaviors and digital platforms.

Compliance Strategies for Registered Advisers

Update Marketing Policies & Supervisory Procedures

Ensure your existing marketing policy includes definitions like “testimonial,” “endorsement,” and “performance” under the new regime. Update your compliance manual to require pre‑approval and documentation for all marketing materials.

Implement Pre‑approval & Testing

Develop a standard process for reviewing every new marketing piece before publication. Ensure tests confirm accuracy, relevance, and compliance with the updated rule’s disclosure requirements.

Vet Testimonials & Third‑Party Ratings

Testimonials, endorsements, and third-party ratings require careful documentation under the new rule. You must disclose material conflicts and include clear explanations about methodology and attribution.

Monitor Social Media and Influencers

Posts by your firm or by influencers about your services are now subject to the marketing rules. Set supervisory oversight, review third-party content usage, and track changes over time.

Operationalizing the Rule

• Train your team on new definitions and approval workflows.
  
• Implement quarterly internal reviews to track compliance performance.
  
• Utilize compliance consulting services or risk management consulting for test reviews and mock audit support.
  

Real-World Examples & Pitfalls to Avoid

• Example Pitfall: Overstating returns by omitting benchmark comparisons.
  
• Compliant Alternative: Presenting models with standardized performance figures and benchmark data, with all relevant disclosures.
  
• Another Pitfall: Publishing client testimonials without documenting consent or business relationship.
  
• Compliant Approach: Only using testimonials with written release and clear attribution.
  

Conclusion

The new investment adviser marketing rule represents a transformative shift in compliance expectations. From redefining advertising to tightening scrutiny around testimonials and performance claims, it demands proactive action. Firms must update policies, train staff, and align their oversight programs with 2025 changes.

If you’re planning to review your marketing practices under the new rule, Quadrant Regulatory Group can help you develop updated policies, implement pre‑approval workflows, and train your team comprehensively. Stay ahead of the transition and maintain confidence in your firm’s compliance posture.