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Testimonial Rule and Social Media Intersect in Recent Enforcement Actions

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On July 10, 2018, the SEC settled enforcement actions brought against two SEC-Registered Investment Advisers (RIAs), three Investment Adviser Representatives (IARs), and a marketing consultant, for their involvement in violating the Testimonial Rule using social media and the Internet. Rule 206(4)-1(a)(1) under the Investment Advisers Act sets forth what types of advertisements are prohibited. The rule prohibits express or implied testimonials. Although the word “testimonial” is not defined in Rule 206(4)-1, it has been interpreted as being a statement of

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Welcome to Smart RIA

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Friends and colleagues: Thank you for taking a moment to visit us at Smart RIA, Automated Compliance Software. We are the first, and currently, the only, truly automated compliance software available on the market. For the compliance portion of our software alone, Smart RIA is a huge time, stress, and money saver for our users. We know, because we use it ourselves in our own firm!

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