206(4)-1
— SEC Marketing Rule · every clause
Marketing reviews · Rule 206(4)-1
Every post, ad, and pitch deck,
Every post, ad, and pitch deck,
cleared before it ships.
Advisors paste a draft. RegFin's AI reviews it against the SEC Marketing Rule (performance claims, testimonials, sponsored content, hypothetical returns, the works) and lands a clean version, or a clear edit list, on the CCO's desk in seconds. Every approved piece is archived with the version that ran.
SC
Sarah ChenAdvisor · draft
LinkedIn ad
"Our model portfolio beat the S&P 500 by 6.4% last year — and my favorite client said it changed the way she sleeps at night. Talk to me about how we can do the same for you."
— Posting Apr 14
— Audience: HNW prospects
!
Critical
Performance claim missing context
"Beat the S&P by 6.4%" reads as a presented performance result. Marketing Rule §206(4)-1(d)(1) requires net-of-fees presentation with equal prominence, time-period framing (1/5/10 yr), and gross/net comparison.
!
Warn
Testimonial trigger phrase
"My favorite client said…" implies a client endorsement. Triggers testimonial disclosures under §(b)(1) — compensation status, material conflicts, fact-vs-opinion label.
✓
Pass
No prohibited language detected
Cleared on Marketing Rule's seven general prohibitions: no untrue statements, no material omissions, no unsubstantiated claims beyond the flagged ones.
<1min
— Typical AI review time
7
— General prohibitions checked
100%
— Approved pieces archived with what ran
Marketing review software for RIAs
Marketing review software lets an RIA clear every advertisement against the SEC Marketing Rule (Rule 206(4)-1) for performance claims, testimonials, and hypothetical returns before it's published. RegFin pre-screens each draft with AI, routes it to the CCO for approval, and archives the approved version, the recordkeeping backbone of RIA advertising compliance.
The review loop
From draft to approved in three stages.
RegFin handles the rule-mechanical part of marketing review so your CCO can focus on the judgment calls.
— 01 · Submission
Advisor
Paste the draft. Pick the channel.
Advisors submit drafts in seconds: a LinkedIn ad, email newsletter, pitch deck slide, podcast script, website page, even a printed brochure. RegFin captures the channel, the audience, and the date it's going live.
- Paste copy or upload a creative
- Set audience, channel, go-live
- Stamp time of submission
→
— 02 · AI review
RegFin · seconds
The Marketing Rule, applied.
Every clause of Rule 206(4)-1 is checked: performance presentation, testimonials, endorsements, third-party ratings, hypothetical performance, predecessor performance, the seven general prohibitions. Each finding cites the section it implicates.
- Inline edits with rule citation
- Severity-ranked issue list
- Suggested compliant rewrites
→
— 03 · Approval + archive
CCO
One queue. One decision. One audit trail.
The CCO reviews only what needs human judgment; clean drafts move straight to approval. Once approved, the exact version that ran is archived alongside the AI findings, CCO sign-off, and the rule citations evaluated.
- Approve, request edits, or reject
- Pinned to the live version that ran
- WORM-sealed for exam evidence
Every channel · one workflow
If it counts as an advertisement, RegFin reviews it.
Under the Marketing Rule, "advertisement" is broad. RegFin's reviewer handles every format an RIA marketing team actually produces.
LinkedIn posts & ads
Personal posts, company-page posts, sponsored content, and InMail templates.
Facebook & Instagram
Page posts, ads, stories, reels, and DM templates from advisor business accounts.
X & YouTube
Threads, video scripts, on-screen text overlays, descriptions, and channel-bio copy.
Email & newsletters
Monthly market updates, prospect drip sequences, holiday letters, event invites.
Website & landing pages
Marketing site pages, blog posts, lead-magnet PDFs, landing-page hero copy, FAQs.
Pitch decks & one-pagers
Prospect decks, model overviews, performance one-pagers, capability statements.
Brochures & PDFs
Form ADV Part 3, fact sheets, brochure supplements, attribution disclosures.
Podcasts & events
Podcast scripts, conference talk decks, sponsored-segment copy, webinar slides.
Marketing Rule · trained
The whole 206(4)-1.
RegFin's reviewer is built around the Marketing Rule, its adopting release, and SEC Risk Alerts and FAQs, plus a curated body of state-level guidance. Every flag in a review traces back to a specific clause.
The model doesn't try to be a lawyer. It surfaces the issue, cites the rule, suggests a compliant rewrite, and hands the judgment back to your CCO.
Beyond the Marketing Rule itself, the reviewer also enforces your firm's own marketing policies: required disclaimers, banned phrases, attribution standards, channel-specific rules, whatever your compliance manual prescribes. SEC rules and firm rules, checked in the same pass.
§206(4)-1 · effective Nov 4, 2022§(a)
"Advertisement" definition
Direct or indirect communication offering services to prospects or new investors in private funds; the scope test for everything below.
§(b)
Testimonials & endorsements
Compensation disclosure, material conflict disclosure, fact-vs-opinion labeling, and the bad-actor disqualification check.
§(c)
Third-party ratings
Reasonable basis for the rating, date and period covered, and disclosure of any compensation paid for inclusion.
§(d)(1)
Gross/net performance
Net-of-fees presentation required, equal prominence with gross, and time periods of 1/5/10 years (or since inception).
§(d)(2)
Hypothetical performance
Distinct standards depending on intended audience, with required disclosures around assumptions, limitations, and the basis for projections.
§(d)(3)
Predecessor performance
Must be performance the same key personnel are primarily responsible for, with continuity disclosures and equivalency justification.
§(e)
Seven general prohibitions
Untrue statements, unsubstantiated claims, omissions of material fact, reference to specific advice without context, mischaracterized cherry-picked results, and more.
Hard-to-get-right corners
The two areas examiners are reading line-by-line.
— Testimonials & endorsements
The biggest landmine since the 2022 amendment.
Client quotes, solicited endorsements, podcast guest testimonials, paid social promotions: they all need the compensation and conflict disclosures done right. And even unsolicited content like Google reviews or social shoutouts can trigger the rule the moment your firm adopts or highlights them.
- Detects implicit testimonials in advisor-authored copy
- Generates the required disclosure footer for the channel
- Maintains the firm's list of compensated promoters with effective dates
- Flags bad-actor disqualifications before a promoter is published
— Performance presentation
The clause CCOs lose sleep over.
Gross/net equivalence, hypothetical performance, model results, back-tested performance, extracted performance: RegFin checks the disclosures required for whichever presentation type applies.
- Checks gross/net presentation prominence
- Verifies the 1/5/10-year time-period framing
- Identifies hypothetical performance that needs §(d)(2) treatment
- Surfaces missing standardized disclosures (fees, methodology, assumptions)
FAQ
The questions a CCO actually asks.
No. The AI does the rule-mechanical pass (finds the testimonial trigger, the missing net-of-fees disclosure, the cherry-picked time period) and produces a complete edit list with citations. The CCO still approves or rejects. What changes is what the CCO is spending time on: judgment calls and edge cases, not searching the rule text for which clause a performance claim might trip.
Unsolicited content doesn't trigger the Marketing Rule until your firm adopts it: sharing a Google review on your website, reposting a client quote on LinkedIn, or featuring a testimonial in a pitch deck. When an advisor wants to use that content, they submit it through the same review workflow as any other marketing piece. RegFin checks the required disclosures (compensation status, material conflicts, fact-vs-opinion labeling) and archives the approved version. For content your firm chooses not to adopt, RegFin helps you maintain a documented non-adoption policy, which is exactly what examiners want to see.
Yes. Beyond the Marketing Rule itself, the reviewer enforces your firm's specific marketing policy: required disclaimers, banned phrases, required attribution for performance data, and any state-specific overlays. Edits to the policy take effect on the next review.
The exact version that ran (copy, creative, channel, audience, go-live date), plus the AI finding list, the CCO sign-off with note, the rule clauses evaluated, and a hash. If you later edit or remove the piece, the previous versions stay sealed with diffs. Exam pull is one click.
For a paste-and-submit LinkedIn ad or email blast, the AI pass typically returns in under a minute. CCO review of a clean draft typically takes under two minutes; a multi-issue draft with edits takes whatever back-and-forth the firm normally does, but every round of edits is captured in the record.
Yes. §(d)(2) is one of the trickiest clauses in the rule, and the reviewer handles it directly. It detects hypothetical performance, model results, and back-tested returns, then checks for the required disclosures: assumptions used, limitations of the results, and risks specific to hypothetical projections. Audience context matters too: hypothetical performance shown to retail investors triggers stricter requirements than the same content directed at qualified purchasers. The reviewer flags the gap, cites the section, and hands the judgment to your CCO.
After approval
Review once. Reuse forever.
Approved materials don’t disappear after the CCO signs off. They go into your Approved Content Library. Advisors browse, pick, and deploy pre-cleared marketing content without re-triggering the review process. Customize a piece? AI pre-screens the changes before it hits the CCO’s desk again.
One approval. Unlimited deployments. Every use archived with full provenance.
See the Content Library →
See it in action
Marketing review that actually keeps up.
We'll walk you through the full review workflow: submission, AI analysis, CCO approval, and the versioned archive your examiner will see.
Book a demo →