Outbound, content and web operations for registered investment advisers, operated by us. Referrals and centers of influence drive 67% of new clients and new client assets in this industry (Schwab RIA Benchmarking Study, 2024) and almost nobody works them on a cadence. We do, alongside prospecting on real liquidity events and the client proof the Marketing Rule allows, documented as the program runs.
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Two lanes. Prospects reached on real liquidity events, and the centers of influence that have always driven this business: CPAs, attorneys and the custodians and platforms whose referral programs most firms never work.
The client proof the Marketing Rule opened up, plus the thought leadership that earns a first meeting from someone who has never heard of you.
Placement and commentary in financial media, which in a category built entirely on trust is the strongest signal you can buy and the hardest for a competitor to copy.
The site, the disclosures and the documentation trail that has to survive an examination without anyone reconstructing it afterwards.
None of this is legal advice and your chief compliance officer still signs. It is here because it is the difference between us and a generalist agency, and because one of these four rules opens a door instead of closing one: the documentation is produced as the program runs, not reconstructed when it is examined.
The rule permits testimonials and endorsements in adviser marketing, subject to disclosure and oversight conditions. Before it was adopted they were effectively off limits.
What that means for a campaign: This is the only rule on this site that opens a door instead of closing one, and a striking number of advisers still market as if it had not changed. Client proof is the most persuasive asset in this category and it has been available for years.
A promoter compensated more than $1,000 over a twelve-month period requires a written agreement with the adviser.
What that means for a campaign: The threshold is cumulative over a rolling year, so a referral arrangement that starts as a favour crosses it quietly. Whoever runs the program needs the running total, not a memory of what was paid last quarter.
The definition reaches communications sent to a single recipient, and covers digital media, video, social platforms and websites.
What that means for a campaign: One to one is in scope, which removes the usual escape hatch that it was only an email. Everything an adviser sends is marketing, so the review surface is the whole outbound volume, not the campaign assets.
Advisers using compensated testimonials or endorsements adopt policies designed to ensure the arrangements comply, including documentation supporting a reasonable belief of compliance.
What that means for a campaign: Reasonable belief has to be evidenced, which in practice means the documentation is the deliverable. A program that works but cannot show its paperwork fails the examination it passes in spirit.
The line you cannot cross: Never present performance without the disclosures the rule attaches to it, and never let a compensated endorsement read as spontaneous. The disclosure is what makes the proof usable, not what weakens it.
Referrals are a channel, not an absence of marketing, and almost nobody works them as a channel. The centers of influence who send you clients need material, cadence and a reason to think of you this quarter. That is the same machinery, pointed at the people who already trust you.
That is usually a memory of the pre-2020 regime rather than the current rule. Testimonials, endorsements and compensated referrals are permitted with disclosure, oversight and documentation. What we produce is the documentation as much as the campaign, so what reaches your CCO is already the version that survives an examination.
Good, we replace none of them. Those hold the book, the relationship and the record. This is the layer that creates what gets archived: the message, the asset, the sequence, and the trail that shows how each one was approved and when it went out.
Yes. The SEC Marketing Rule permits testimonials and endorsements in adviser marketing, subject to disclosure and oversight conditions, and has done since 2020. Before that they were effectively prohibited, which is why most firms still market as if they were. The single most persuasive asset you own has been sitting unused for years.
When a promoter is compensated more than $1,000 over a twelve-month period. Below that threshold the written agreement is not required, above it it is, and the arrangement also has to be covered by policies designed to ensure it complies. The threshold is tracked as part of running the program rather than discovered during an examination.
It can. The definition of an advertisement reaches communications sent to a single recipient, and covers digital media, video, social platforms and websites. That is why outbound here is archived the same way the website is: the distinction between a campaign and a personal note is not where most people assume it is.
Referrals stay the core, and they get worked properly instead of hoped for: CPAs, attorneys and the custodian and platform referral programs most firms never touch. On top of that, outbound on real liquidity events, content that earns a first meeting from someone who has never heard of you, and placement in financial media, which in a category built entirely on trust is the strongest signal you can buy.
Written and reviewed by Martin Weidemann, founder of Fullstack GTM · Last reviewed
Fullstack GTM operates outbound, content, digital PR and web systems. Nothing on this page is legal, compliance, tax or investment advice: the regulations cited are context for how a campaign gets built, not a substitute for your own counsel, and your compliance officer still signs.
We will send you outbound written off real liquidity events in your market and a content read for your practice, within 24 hours. Before any commitment and with no call required.
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