SEC Clarifies “Testimonial Rule” for Advisors

Last month (March, 2014) the SEC released a “Guidance Update” in an effort to clarify the Testimonial Rule [rule 206(4)-1(a)(1)] and how it applies to social media use by, and third-party reviews about, registered investment advisors. The Testimonial Rule states: “[i]t shall constitute a fraudulent, deceptive, or manipulative act, practice or course of business .…