Intro (00:00):
This is Advisor Intelligence, the podcast for investment advisors and financial institutions. In each episode, attorneys from your investment management and securities team break down compliance, regulation and risk into practical insights that help you stay exam ready and ahead of what’s next. This podcast is brought to you by Stark & Stark.
Stephen Galletto, Esq. (00:28):
Welcome back to another episode of the Advisor Intelligence podcast. I am Steven Galletto.
Mittal Patel, Esq. (00:33):
My name is Mittal Patel,
Joseph Antonakakis, Esq. (00:35):
And I am Joseph Antonakakis
Stephen Galletto, Esq. (00:38):
]And within this episode, we’re going to be discussing the SEC’s new marketing rule. Relatively new. It’s been out for about four years, right, Joe?
Joseph Antonakakis, Esq. (00:45):
It’s been out for four years, and they have started enforcing it.
Stephen Galletto, Esq. (00:49):
They have been enforcing it heavily for
Joseph Antonakakis, Esq. (00:52):
At least two years past
Stephen Galletto, Esq. (00:52):
The past three.
Joseph Antonakakis, Esq. (00:53):
Yeah,
Stephen Galletto, Esq. (00:54):
More particularly last year. They were on a war path.
Joseph Antonakakis, Esq. (00:57):
Yeah. Not only were they on a war path, they did specific marketing rule exam sweep where they were going to a lot of our clients; I worked with probably a dozen who just got examined only on the marketing rule. And unfortunately, we saw a lot of fines for what I would say are relatively minor violations of the rule.
Stephen Galletto, Esq. (01:19):
But they were going after larger firms. They were trying to make an example. They were trying to set the stage for what they were going to do with this marketing rule.
Joseph Antonakakis, Esq. (01:26):
Well, I don’t know if I should give specifics.
Stephen Galletto, Esq. (01:29):
Oh, please do.
Joseph Antonakakis, Esq. (01:30):
But what I will say is
Stephen Galletto, Esq. (01:32):
Spill the tea, spill it.
Joseph Antonakakis, Esq. (01:33):
I’m spelling the tea
Stephen Galletto, Esq. (01:35):
All of the tea
Joseph Antonakakis, Esq. (01:36):
In a manner that is consistent with my
Stephen Galletto, Esq. (01:39):
fiduciary and ethical duties,
Joseph Antonakakis, Esq. (01:40):
With my duties as an attorney.
Stephen Galletto, Esq. (01:43):
In case anyone didn’t know we are actually all attorneys.
Joseph Antonakakis, Esq. (01:45):
It’s true, but I saw a smaller advisor, low hundreds of millions of dollars in assets under management.
Stephen Galletto, Esq. (01:57):
So definitely SEC registered definitely under the rule.
Joseph Antonakakis, Esq. (01:59):
SEC registered, falls under the rule. But the regulators fined him for, again, relatively minor violations, in my view, find him $60,000 for violations of the rule. So this isn’t a huge advisor.
Stephen Galletto, Esq. (02:15):
What was the violation or what were the violations ?
Joseph Antonakakis, Esq. (02:18):
Alleged violations, which were neither confirmed nor denied, nor admitted to were lack of disclosures on certain third party ratings, rankings, and awards that this individual was advertising.
Stephen Galletto, Esq. (02:32):
Was this an old award or was this like a standard sort of award from Barron’s or,
Joseph Antonakakis, Esq. (02:38):
I will say it was an old award. It was sort of, I’m going to call it throwaway. In other words, it was just somewhere in some marketing materials that probably very few people
Stephen Galletto, Esq. (02:50):
Got
Joseph Antonakakis, Esq. (02:51):
Did not result in any new clients to the firm, and yet the individuals still, the SEC went after the firm and find them $60,000. And I had another client who similar issue, a little bit larger, but again, lack of disclosures on third party ratings, rankings and awards, and displaying those awards in a manner that is inconsistent with the rule, which we’ll talk about in probably a moment. They were fined $150,000.
Stephen Galletto, Esq. (03:21):
Got it.
Joseph Antonakakis, Esq. (03:22):
So we see fines from large advisors to relatively small advisors. So you made a good point that most of them were probably folks who are larger. They were trying to sort of make an example out of them, so to speak, but there were some smaller folks caught up in that as well.
Stephen Galletto, Esq. (03:40):
Right. For those of you who have not been introduced to Mittal yet, haven’t worked with HEL yet, HEL has somewhat of an interesting background in past. She spent three semesters with the SEC interning during her undergraduate and during her law school career. But any background you want to share from your time at the SEC and how they try to enforce these rules.
Mittal Patel, Esq. (04:05):
So when the SEC comes in and does an examination, they like to get their hands on all available materials. They’re going to request materials, but then they’re also going to be reviewing your website. So when they’re reviewing your website, we want to make sure that if there’s any testimonials, endorsements, third party rankings or awards, that there are the appropriate disclosures. If there’s no disclosures, the SEC is going to put that in your deficiency letter, but when we draft these disclosures, we want to make sure that they’re properly displayed on the websites. We don’t want to hyperlink them to another page because the SEC does not like that as they indicated in their alert. Also, we want to make sure that the disclosure language is not in a small font. The SEC likes to make sure that they’re clearly displayed
Stephen Galletto, Esq. (04:49):
Needs to be legible.
(04:50):
Right.
Mittal Patel, Esq. (04:50):
Yeah. And then the other thing is the SEC really wants to see for awards and ratings. When was the award or the rating given?
Stephen Galletto, Esq. (04:58):
Right
Mittal Patel, Esq. (04:58):
Is it from a valid source? Was compensation given in any form?
Stephen Galletto, Esq. (05:03):
So if you have an award from 2003 on your website, right? I was a top advisor in 2003, and that’s the only time I was a top advisor by this ranking system. Is that relevant?
Mittal Patel, Esq. (05:14):
Not necessarily because there’s been, it’s 22 years since that award has been given. And can we still substantiate or prove that we are the best award.
Stephen Galletto, Esq. (05:26):
Good quick math, by the way. Nice. Alright. Also, Mittal was a math major. I’m spilling all mythos tape. She’s very, very reserved with taking credit where credit is due. So I’m just going to keep on propping up mytho this entire time. Good job.
Mittal Patel, Esq. (05:43):
Thank you, Steve.
Joseph Antonakakis, Esq. (05:43):
Yeah, and Mittal, you pointed out something really good, which is the website review, and this is something that folks very often forget about,
Stephen Galletto, Esq. (05:50):
but it’s right there. It’s so easy to get to it.
Joseph Antonakakis, Esq. (05:52):
It’s easy to get to.
Stephen Galletto, Esq. (05:53):
Also, they get to it before they even tell you they’re auditing you. Yeah, that’s right.
Mittal Patel, Esq. (05:56):
I speak to that from my experience,
Stephen Galletto, Esq. (06:01):
They didn’t just randomly figure out that your website had this on there after they started the audit. They knew. They knew it was there.
Joseph Antonakakis, Esq. (06:06):
Yeah, they definitely knew. And I mean, we minol, you can attest to this because you do a lot of these as well, but probably on an annual basis we’re doing a hundred plus reviews of websites for advisors.
Mittal Patel, Esq. (06:17):
Absolutely.
Joseph Antonakakis, Esq. (06:17):
I mean, we have a lot of clients across the country and at least a hundred of them we’re doing collectively as a group on an annual basis. And so the website, we will talk in a second about what is a testimonial and an endorsement and a ranking in such. But oftentimes when those things are on the website, the regulators are seeing them. And the other thing that’s notable is, and probably about six months ago, the SEC announced they were going to start using artificial intelligence.
Stephen Galletto, Esq. (06:47):
Oh God.
Joseph Antonakakis, Esq. (06:48):
In their exam process,
Stephen Galletto, Esq. (06:50):
Not advisor intelligence. They’re not using us, we are not pawns.
Joseph Antonakakis, Esq. (06:52):
They’re not using advisor intelligence. They’re using artificial intelligence to help them perform exams.
Stephen Galletto, Esq. (06:59):
So chat gpt is reviewing everyone’s website saying, Hey, SEC, we think this is a problem.
Joseph Antonakakis, Esq. (07:03):
Well, pretty much that’s how I would imagine them using it is they’re going to go to somebody’s website
Stephen Galletto, Esq. (07:08):
Or is there a way to train chat GPT in a way so that it just misunderstands all of this information, all these issues on these advisors.
Joseph Antonakakis, Esq. (07:15):
We’ll have, talk to Sam Altman and OpenAI about that.
Stephen Galletto, Esq. (07:18):
We need to counter counteract the SEC’s use of ai.
Joseph Antonakakis, Esq. (07:23):
Just for the record, I don’t want to counteract anything the SEC does. I’m all about compliance and complying with the regulators. Steve might not be.
Stephen Galletto, Esq. (07:30):
You coward. Have you guys seen any different application across different SEC offices, different regional offices of the SEC, applying the marketing rule to advisors in different sections of different regions? From my perspective, I’ve seen it pretty evenly handled across the country, which to me signals that there’s someone at the top telling everyone exactly how to interpret. It’s not like Chicago is interpreting the testimonial issue differently than New York or dc. And so this is obviously a high priority issue and consistency is key in the investment advisor space if we want to avoid SEC issues.
Mittal Patel, Esq. (08:16):
Yeah, I completely agree with it. From the deficiency letters I’ve drafted and for deficiencies related to the marketing rule, the deficiencies are consistent.
Joseph Antonakakis, Esq. (08:27):
Can we just talk for a second, if you don’t mind? We’re talking sort of amorphously about testimonials and endorsements and ratings and such. I would love to, for those folks out there who are wondering what they are, how they can use them, whether they can use them. Testimonial is going to be a statement from an existing client that describes or promotes in some way the services that the firm provides.
Stephen Galletto, Esq. (08:52):
Okay.
Joseph Antonakakis, Esq. (08:52):
So Steve GoTo, investment advisors, if I’m a client and you say to me, Hey, Joe, I would love for you to leave me a review on Google, or I’d love you to provide a paragraph on why you like working with me, or something along those lines that’s considered a testimonial existing client of the investment advisory firm providing a statement outlining the position.
Stephen Galletto, Esq. (09:11):
Does it matter if I pay you or not?
Joseph Antonakakis, Esq. (09:14):
Well, sort of yes and no. I mean, that’s one of the things, what does it affect? Well, it affects the disclosure language that you need to put alongside the testimonial. So when you’re dealing with testimonials, there’s sort of two compliance areas. You have compliantly obtaining the testimonial, and then compliantly advertising the testimonial.
(09:37):
When you’re asking for testimonials, the key is not cherry picking which clients you think are going to provide the best testimonials. So for example, if we go back to Steve Galletto, RIA, if you think Mittal is a better client than I am, or she’s smarter or she, this is all, yes, this is all true just aside, or she’s performed better in the market than you have for me, and you want to go to Mittal instead of me for a testimonial, that’s a problem. The regulators are going to say, you are cherry picking which clients you want to provide a testimonial.
Stephen Galletto, Esq. (10:10):
So we got to be fair and balanced with how we’re actually getting these testimonials,
Joseph Antonakakis, Esq. (10:12):
Fair and balanced with requesting testimonials.
Stephen Galletto, Esq. (10:16):
Got it.
Joseph Antonakakis, Esq. (10:17):
So that’s obtaining testimonials. So you have to ask pretty much everyone, all of your clients, for a testimonial if you’re going to advertise it.
Stephen Galletto, Esq. (10:25):
And when I’m recommending don’t, first of all, I don’t recommend using testimonials because again, it’s an untested area. I am always going to be conservative when I’m providing advice to clients about how to interact with the marketing rule because to a large extent, it’s untested in certain areas like tested testimonials like endorsements.
Joseph Antonakakis, Esq. (10:47):
Well, the SEC has come out with a little bit of guidance, especially towards the end of 2025. They came out with, I think it was in the first week or second week of December, they came out with a risk alert where they outlined sort of what they’ve been seeing during exams as it relates to the marketing rule broadly, not just testimonials, what they’re seeing during exams, where they’re seeing people deficient, which is a lot of the things that we’re talking about right now, particularly the disclosures, which we’ll touch on in a second too. But they’re starting to provide a little more guidance. So it’s becoming a little bit easier as attorneys and as advisors to comply with these rules. We know where people have been messing up, we know what the rule says, we know what the guidance is from the regulators. And so it’s becoming easier to comply
Stephen Galletto, Esq. (11:37):
Because I’ve been doing this for a while. I know the first pass is not necessarily the last pass with how the SEC wants to enforce on these things conservatively. Again, when clients ask if they can use testimonials, I say yes, but we need to make sure that we do this in the best possible way. We need to make sure we’re asking all clients, we need to make sure that this is an ongoing thing. We can’t just ask everybody after a fantastic year of performance, Hey, can you leave me a testimonial? Market knows dives for the following year and the year after everyone’s recovering and we don’t ask anybody again, it needs to be a living, breathing thing in order for it to be relevant.
Joseph Antonakakis, Esq. (12:16):
Well, what I think is easy for folks, because number one, it keeps it updated. Number two new ones can be added easily, is things like Google Reviews. And Mittal, you probably see this pretty often as well.
Mittal Patel, Esq. (12:29):
I see a lot of Google reviews on the websites when I review them. And one of the things I always tell clients is, you can’t just cherry pick the best Google reviews and put them on your website. That goes back to the element of fair and balance. If there’s a bad Google Review, we’d also need to make sure our clients or prospective clients have exposure to it. So if you embed Google reviews into your website, you need to make sure that all prospective and current clients have access to all the Google reviews.
Stephen Galletto, Esq. (12:58):
So if someone’s going to take, I dunno, five or six Google reviews all of their best Google reviews and put them on their website, that’s going to be a
Mittal Patel, Esq. (13:07):
Problem. Yeah, the SEC will definitely flag that.
Stephen Galletto, Esq. (13:09):
Can you throw disclosure on your website pointing back to Google for the balance of those reviews? Should you potentially have a rotating scrape of the Google reviews and switch out those reviews? So sometimes, I don’t know, maybe you get a really ridiculous or terrible one that just pops up on your website, right? Because if it’s really fair and balanced and you have to reference all of your testimonials on Google, do you need to have that crazy person that thought they were leaving a review for an Amazon product on your Google reviews? Does that have to pop up on your website?
Mittal Patel, Esq. (13:45):
Yeah,
Stephen Galletto, Esq. (13:46):
Right. Because not so easy to take stuff off of Google Now, is it?
Mittal Patel, Esq. (13:49):
No.
Stephen Galletto, Esq. (13:49):
That’s one of the reasons why I think a Google review is a good place to go because Google has their own standards for what’s acceptable and what’s not, and how you can have it pulled down what is offensive, things along those lines. So there are parameters in place to actually limit that aspect of it as well.
Joseph Antonakakis, Esq. (14:09):
And the other thing that I just want to touch on testimonials is the disclosure aspect.
(14:13):
So we were talking about in a lot of the exams that we saw, lack of disclosure is where we saw the fine, not because the award was incorrect, not because they had testimonials, but because they didn’t have disclosures, corresponding disclosures alongside those testimonials or third party ratings and rankings. So it’s critically important when you’re advertising testimonials, whether it’s on your website or whether it’s on Google, that you have those disclosures available directly outlining whether this person is a current client, whether or not they were compensated any conflicts of interest that may exist. And these have to be, like you guys mentioned, they have to be prominent. You can’t just link to the disclosures on a separate disclosure page. It has to be prominently displayed alongside the advertising material, the testimonial or the ranking.
Stephen Galletto, Esq. (15:07):
And again, going back to what I was saying, again, not to be paranoid, but again, this is the first pass, right? Disclosure is a baseline, right? There could be other things at some point in the future, the SEC is going to look at and say, you know what? Looking at this, we think this is inappropriate. Or maybe this award is not consistent with can’t used consistently within this space for whatever reason. Maybe it is not really relevant to the investment advisory space. We’re not talking about Baron’s Awards, we’re talking about employment awards or regional philanthropy awards or something like that. The SEC could take issue with these things at some point. We can’t control that, right? All we can do is work with the guidance that we currently have right now. All of those additional rewards are perfectly fine as long as there’s adequate disclosure there.
Joseph Antonakakis, Esq. (15:56):
Precisely.
Stephen Galletto, Esq. (15:56):
But again, compliance is an ever evolving and ever changing space. So for the time being baseline, just make sure the disclosure is appropriate and then keep an eye out for compliance alerts and compliance updates from Stark & Stark advising you of new guidance and new information about these sorts of things, because things change all the time.
Joseph Antonakakis, Esq. (16:17):
I’m glad you brought up third party ratings, rankings and awards. I mean, you were talking about Barron’s and you were talking about Forbes and Five Star and such. And the other thing you mentioned, which I really appreciated, were things that are not necessarily financial related, like a best place to work or a top philanthropist or something along those lines. And you’re exactly right that currently it’s sort of ambiguous as to whether those count as third party ratings, rankings and awards under the marketing rule. And so what we’ve been advising folks is
Stephen Galletto, Esq. (16:50):
Comply,
Joseph Antonakakis, Esq. (16:51):
If you’re going to post that on your website or on your LinkedIn or on wherever it may go on social media or whatever the case may be, you got to have the disclosures alongside any third party rating, ranking and award. I’ve seen instances where folks have them sort of in their LinkedIn bio where they’ll say, received 2026 top investment advisor from Barron’s, or something along those lines. You need to have corresponding disclosures. Even there, there’s sort of two parts to complying with third party ratings, rankings and awards. There’s making sure that the award is valid. You have to do some level of due diligence to make sure that it’s not sort of a made up or a fictional or an invalid or an unfairly provided award. So there’s some level of base due diligence for the firm to do on the award. And then again, when you receive it and you’re advertising it, making sure you have those specific disclosures alongside those awards. Do you want to talk about what those disclosures are?
Mittal Patel, Esq. (17:50):
Absolutely. So the first element is we need to identify who actually gave you the award, which company awarded it. So
Joseph Antonakakis, Esq. (17:59):
If it’s a Barron’s or a Morningstar or a Forbes, that’s like part one.
Mittal Patel, Esq. (18:03):
We need to identify who awarded it when you receive the award and what the time period of the award was. What was their time period based off of their selection process.
Joseph Antonakakis, Esq. (18:15):
So it could be, sorry to interrupt you, but in a sense, I want to kind of build out this disclosure as we’re going through element by element. So this award was provided by Forbes
Mittal Patel, Esq. (18:26):
On the state
Joseph Antonakakis, Esq. (18:27):
On December 22nd, 2025 for the date range considered January through June, 2025.
Mittal Patel, Esq. (18:36):
Yes.
Joseph Antonakakis, Esq. (18:37):
And then
Mittal Patel, Esq. (18:37):
The next one is the methodology that the award company used to award you the award. So what is their selection criteria? And we should make that available in the disclosure.
Joseph Antonakakis, Esq. (18:49):
And then the final one is compensation.
Mittal Patel, Esq. (18:52):
Yes. So we want to disclose whether the advisor paid any compensation to be considered for the award,
Stephen Galletto, Esq. (19:00):
Like an application fee or something like that?
Mittal Patel, Esq. (19:01):
An application fee, or whether they paid any compensation to actually display that they received the award,
Stephen Galletto, Esq. (19:09):
Which is very common. Plaques are all over the place. Oh, not just plaques, but also the ability to use the mark on a website.
Joseph Antonakakis, Esq. (19:16):
Precisely. Yeah.
Mittal Patel, Esq. (19:17):
And it’s interesting that she mentioned using the mark on the website. So when an advisor is awarded an award multiple years in a row, we need to make sure that the plaque or the logo actually reflects the years that they’re receiving the award. So for example, if you received the award in 2022, 2023, didn’t receive it in 2024, but received it in 2025, if the plaque still says you received the award in 2024, that’s considered a marketing rule deficiency.
Stephen Galletto, Esq. (19:44):
Correct? Because it’s not true.
Mittal Patel, Esq. (19:46):
Yeah, it’s not true. And we need to make sure that we are using all materials.
Stephen Galletto, Esq. (19:50):
Where do you see references to awards where you don’t see disclosure more often than on agreements?
(19:57):
On agreements?
Mittal Patel, Esq. (19:58):
Yes. And I’ve had the SEC point that out in a deficiency letter.
Joseph Antonakakis, Esq. (20:03):
Sure, Joe, I see it on social media. Somebody might post it on LinkedIn. A firm might say, oh, Steven GoTo won the X, Y, Z best advisor award 2025. And then there’s no corresponding disclosure there.
Stephen Galletto, Esq. (20:18):
I see it 15 times a day when I’m responding to emails. It’s at the bottom in the email signature. Email
Joseph Antonakakis, Esq. (20:23):
Signature. I see that as well.
Stephen Galletto, Esq. (20:24):
Yeah. Can you have a hyperlink there?
Joseph Antonakakis, Esq. (20:27):
No, not even. Yeah, definitely not,
Stephen Galletto, Esq. (20:30):
Right?
(20:31):
Yeah, you need to have disclosure. And if it’s in your email signature and you’re trying to not throw a paragraph at the bottom of every email that you write and it’s at 0.2 font, I don’t care that I can scroll up on that text and then be able to read it. It looks like a disclosure. A redirect is usually not going to win the fight.
Joseph Antonakakis, Esq. (20:50):
And what’s notable about that? What I will say, you mentioned the size of the text. The rule requires that the disclosure is at least as prominent as the award itself. So if somebody has a logo for A-C-N-B-C award or whatever in their email signature, the disclosure does need to be at least as prominent as that award. Now, what I will mention, because you mentioned hyperlinks, I will mention that there’s one part of the disclosure that is allowed to be hyperlinked Mittal, what is it?
Mittal Patel, Esq. (21:23):
It’s the methodology. But if we are including a hyperlink to the methodology, we need to make sure that it actually works and we actually have access to the methodology.
Stephen Galletto, Esq. (21:34):
So it should be routinely reviewed to make sure those links are still kept current.
Mittal Patel, Esq. (21:38):
Yes.
Stephen Galletto, Esq. (21:40):
It’s important, I think because those people that issued awards and rankings may not always issue those awards and rankings that you pull that information, that disclosure down, and that you do keep that internally. If you want to use a hyperlink and you want to host that disclosure language on a website that you control, I think you’re a lot more safe than relying upon a third party to continue doing what they’ve always been doing. Absolutely. Unless you want to pay for it.
Joseph Antonakakis, Esq. (22:03):
Can we talk for just a moment finally, about endorsements?
Stephen Galletto, Esq. (22:07):
I’m not going to endorse you, Joe.
Joseph Antonakakis, Esq. (22:09):
I was hoping you would, but you don’t pay me enough. I don’t pay you at all.
Stephen Galletto, Esq. (22:12):
Exactly.
Joseph Antonakakis, Esq. (22:16):
Endorsements. These are things that, similar to testimonials, statements that are endorsing the firm’s services, but different from testimonials, they’re not from existing clients, they’re from third parties. So if I’m Joe Anton advisory firm, and I hire you or compensate you, Steve Galletto as a non-client to go out and find business for me, you, Steve Galletto are an endorser or a promoter under the SEC marketing rule. This is what’s formerly known as a solicitor now called a promoter or somebody who’s providing an endorsement under the rule. And sort of the disclosure requirements that went along with the solicitor rule also apply to now endorsers. If you want to talk briefly about what the disclosure might look like.
Stephen Galletto, Esq. (23:07):
Well, if you’re going to be paying somebody for referring clients to your firm, the client that’s being referred to, your firm needs to be aware that the person referring them, the endorser or promoter in this instance is receiving some sort of compensation. So much like under the old case solicitation rule, do we need to have the referred client sign a disclosure form, acknowledging that the promoter is actually receiving compensation, what that level of compensation actually is under the new marketing rule, there is not an explicit requirement that there’s a written disclosure form signed by the underlying client, the one that’s being referred. It’s our recommendation or strong recommendation that we still have the promoter get that disclosure form so that there’s clear documentation that the referred client is aware of that relationship. So are there differences? Are there nuances? Yes. In practice and in principle, does it make sense to rely upon those differences? Probably not. Unless you want to take your promoter’s word at it that they provided your A DV, that they told the referred client that they’re receiving compensation for making that referral.
Joseph Antonakakis, Esq. (24:15):
And I just wanted, we all said the word compensation several times throughout this conversation. Compensation, compensation, compensation,
Mittal Patel, Esq. (24:24):
Compensation,
Joseph Antonakakis, Esq. (24:25):
Compensation. We’ve said it several times now. What’s important to note when it comes to compensation for testimonials, compensation for endorsements, compensation for third party ratings, rankings, and awards, that it’s not just direct cash compensation that’s being considered under the rule. It’s also sort of non-cash or indirect compensation. So like you mentioned about third party ratings and rankings, indirect compensation can be we’re paying the company to use their logo. It’s not direct compensation to receive the award. It’s indirect to advertise it. We do have to compensate disclosable conflict of interest. If you’re providing someone a discount to their fee for providing a testimonial, non-cash, indirect compensation must be disclosed. And same with, like you mentioned, promoters, who I would say 99% of the time are being compensated. Compensation is important to disclose.
Stephen Galletto, Esq. (25:26):
I like money.
Joseph Antonakakis, Esq. (25:27):
Not like me though. Well, I think this was a great conversation about the marketing rule. We talked about testimonials, how to properly obtain them, how to properly advertise them. We talked about endorsements, promoters, relationships, and how to adequately disclose those types of relationships.
Stephen Galletto, Esq. (25:47):
We’ve also introduced Mytho to our audience,
Joseph Antonakakis, Esq. (25:50):
That’s right?
Stephen Galletto, Esq. (25:51):
So Mittal has now met five people. Good job. Thank you. Thank you. Five people that are listening.
Joseph Antonakakis, Esq. (25:57):
Yeah. And we’ll save everyone on the next one.
Intro (26:01):
The Advisor Intelligence podcast provides general information and commentary only the content is not legal advice, nor does it create an attorney-client relationship. For more information about Stark & Stark services, please visit our website@starkstark.com.
