4.7.1. Requirements for State-Registered Investment Advisers
NASAA’s model rule defines an advertisement as any communication about investment services that is addressed to more than one person. That means that websites, social media forums, emails, printed reports, and press releases are all considered to be advertisements. The model rule prohibits the following in advertisements for investment advisers and investment adviser representatives:
• Testimonials of any kind—this includes not only testimonials about the IA or IAR in general, but also testimonials about a particular report, analysis, or recommendation provided by the IA or IAR
• References to past recommendations, unless the IA or IAR provides a list of all recommendations he has made for at least 12 months, as well as a statement that any past success is no guarantee of future results
• Any statement that communicates or implies that a graph, chart, formula, or other device can by itself determine which securities are best to buy or sell, or when they should be bought or sold
• Any promises of a free report, research, or a