SEC Rule 206(4)-1
Collect client reviews without guessing at the Marketing Rule.
Verify the reviewer, screen the text against the rule, put the decision in front of a person at your firm, and keep a record you can hand to an examiner. One console, one seat per advisor.
$40 per advisor seat, per month. Less at volume.
Which rules apply to you
Find your registration. Read that one.
Testimonials are not governed by one rule for everybody. The console asks which of these you are and behaves accordingly.
SEC-registered
Since 2021 the SEC has allowed you to use client testimonials. It also requires disclosure on each one, oversight of what goes out, and records you can produce on request. Most firms skip testimonials entirely rather than build that. This is the console that builds it for you.
State-registered
That federal rule governs SEC-registered firms. If you are a state-registered adviser, your own state decides, and the answer is not the same everywhere: some states follow the SEC rule, some still prohibit testimonials, and several are changing right now. Tell the console which state you are registered in and it shows you that state's rule, with the citation, before you collect anything.
Also a broker-dealer
If your firm also carries a broker-dealer registration, FINRA Rule 2210(d)(6) applies to the same testimonial on top of all of that. Say so in settings and the review form asks the question that rule needs, whether the review discusses a technical aspect of investing and what the reviewer's own experience is, and every review you publish carries the not-representative and no-guarantee disclosures. The answers and the acknowledgement go into the record and the examiner export with everything else. Leave it off and your reviewers never see those questions, because a rule that does not bind you should not lengthen your form.
How a review becomes a record
Five stages. A person signs off at the one that matters.
A review does not move forward because a model said it was fine. It moves forward because someone at your firm decided it should, and the console can prove when.
- 1.
Reviewer verifiesThe client submits, then confirms from their own inbox. An unverified submission never reaches your queue, so the record shows a real person behind every review.
- 2.
Advisor confirmsThe named advisor confirms the person was a client, or declines. A declined review stops here and stays in the log.
- 3.
Automated screeningThe review is read against seven Marketing Rule categories. Each finding comes back as a quoted span, a rule citation, a severity, and a plain explanation.
- 4.
Your compliance decisionA person at your firm approves, rejects, or redacts. Nothing publishes on the screener's say-so. The decision, the actor, and the timestamp are all recorded.
- 5.
Immutable archiveApproved or not, the review and every event attached to it are retained with a hash chain you can hand to an examiner.
Automated screening
What the screener reads every review for.
Seven categories, each tied to the rule it comes from. A finding is never just a flag: you get the exact quoted span, the citation, a severity of low, medium, or high, and an explanation you can put in front of your compliance officer.
This is a first pass, not a sign-off.
The screener narrows what a person has to read closely. Approval always rests with someone at your firm, and the log records who that was.
- Testimonials: language that functions as an endorsement without the disclosure the rule attaches to it.
- Guarantees: promises of a result, express or implied.
- Performance claims: returns, rankings, or numbers that carry their own presentation requirements.
- Misleading statements: claims a reasonable reader could take as more than the facts support.
- Personal information: account numbers, balances, addresses, and other detail the client did not mean to publish.
- Profanity: language you would not want beside your firm name.
- Third parties named: other people identifiable in the text who never agreed to appear.
Inside the console
This is the screen you are buying.
One review, screened, with every flag anchored to the words that caused it. Your compliance officer reads the quoted span and the citation, not a score, and then makes the call.
- Nothing is hidden behind a number: the risk pill summarises, the findings underneath say why.
- Approve is the loud button: reject and unpublish stay quiet, because an irreversible action should never be the easiest thing on the screen to hit.
- Either way it is logged: the decision, the person who made it, and the time all go into the chain.
Automated screening
Risk: highScreened Sep 3, 09:14Findings are shown on the original text so the offsets match the record. Screening is a pre-screen; the publication decision is yours.
Working with Dana turned my retirement around. She promised I would never lose money in a down market, and my account is up 34 percent since 2022. Best decision I ever made.
- mediumguaranteesSEC Rule 206(4)-1(a)(1)
"promised I would never lose money in a down market" A promise of a result. Published as written, this presents a guarantee against loss.
- highperformance-claimsSEC Rule 206(4)-1(d)
"up 34 percent since 2022" A return figure carries its own presentation requirements, including the period it covers and how fees are treated.
For your compliance file
The part that matters when someone asks.
Twenty-three kinds of event are written to an append-only log: submissions, verifications, screenings, decisions, redactions, exports, and every settings change. Reading the forensics is itself logged.
A zip with a cover sheet, every review with its disclosures and timestamps, the full audit chain with hashes, the screening reports, and a manifest carrying the SHA-256 of each file.
- Disclosure on every published review: whether the reviewer is a client, whether anything of value was given, the conflicts that come with it, and the FINRA not-representative and no-guarantee lines, attached to the review rather than buried in a footer.
- Nothing is deleted: a withdrawn or rejected review stops being public and stays in the record, which is what a books and records obligation actually asks for.
- Redaction without destruction: cut a span that names a third party or exposes account detail, and the original, the edit, and the person who made it all remain in the chain.
- Expiry you set: reviews age out on your schedule instead of standing as current advertising forever.
- Roles, not a shared login: advisors, compliance officers, and firm administrators each see and do different things, and the log names the individual.
Your firm, out front
Your name and logo on everything a client sees.
Set your display name, upload your logo, and pick your color. Every page a client lands on and every email they receive carries your firm, not ours. Replies route to your compliance address.
- Display name: emails arrive as your firm, sent through FiduciaryCheck.
- Logo and color: PNG, JPEG, or WebP up to 512 KB, plus a hex color applied across the reviewer experience.
- Your reply-to: a client who answers an email reaches your compliance contact directly.
One line stays, on purpose.
Every branded page and email carries:
Verified and archived by FiduciaryCheck
That line is the product. A testimonial your own firm collected, screened, and published is a testimonial your firm vouches for alone. This one says an independent party held the record and can produce it. Removing the attestation would remove the reason it carries weight, so it is not an option we sell.
Reviews stay hosted with us. There is no separate domain to configure or maintain.
Pricing
One seat per advisor being reviewed.
Seats are counted by the advisors you collect reviews for, not by how many people log in. Compliance officers and administrators do not consume a seat. Annual billing is ten months, so two are free.
Each band applies to the seats inside it, so adding a seat never reprices the ones below it. Set your seat count below to see the invoice.
Compliance officers and administrators do not use a seat.
or $3,750 a year, which is ten months, so two are free.
| Band | Seats | Each | Subtotal |
|---|---|---|---|
| First 5 seats | 5 | $40 | $200 |
| Seats 6 to 20 | 5 | $35 | $175 |
| Seats 21 and up | 0 | $30 | $0 |
| Total | 10 | $375 |
Each band applies only to the seats inside it, so adding a seat never reprices the ones below it. Rates run $40, $35, $30 per seat per month as your firm grows.
- Everything is included: screening, disclosures, the audit chain, redaction, and the examiner export. There is no compliance tier to upgrade to.
- Change seats when you need to: add or remove advisors through the billing portal and the charge follows.
- Card on file, charged at signup: you enter a card on the next screen and are billed for the seats you chose.
- If a payment fails: you get a 14-day grace period, then the console goes read-only. Your records stay readable and exportable. Nothing is deleted.
Already a Fiduciary Check member? You may already have this.
The console is included with Plus and Studio memberships, and with Plus firm plans, at no additional charge and with no seat purchase. Basic memberships do not include it. Sign in and open Compliance from your account.
Fiduciary Check provides review collection, screening, and recordkeeping tooling. It does not provide legal or compliance advice, and the automated screener does not substitute for your firm's own review under SEC Rule 206(4)-1. Your compliance officer decides what is published.