In our first marketing webinar of 2021, Chief Evangelist of Twenty Over Ten & FMG Suite Samantha Russell and Max L. Schatzow, Esq. of Stark & Stark shared insight into the long-anticipated SEC changes to the advertising and solicitation rules. Click play below to learn what your firm can do to prepare and the five biggest marketing opportunities that lie ahead.
The content in this blog post is the result of Twenty Over Ten’s interpretation and Twenty Over Ten is not a compliance expert. Information herein should not be considered legal advice and financial advisors should consult with consult the appropriate authorities as needed including the SEC.
- Always check with your compliance team so that you can make sure you can get everything cleared first before implementing any new marketing strategies.
- The new rules will go into effect 60 days after publication in the Federal Register, which hasn’t quite happened yet.
- Google Reviews-Find out how to execute Google Reviews in order to improve your organic search rankings
- Client Videos-Leverage client recorded videos
- Social Media Comments-Boost engagement on social media through commenting
- Testimonials-How to tastefully incorporate reviews and testimonials on your website
- Client Successes-What are some creative ways for other marketing assets that incorporate client success stories
1. Google Reviews [8:19]
Claim Your Listing And Complete It Fully
When you go to Google and get your listing, then many times the top results that come up are going to be the businesses or services that have reviews. You will notice that you see a “location map,” so when you are looking for something local to your area, Google wants to show you businesses that are best for you. So, make sure you are claiming your listing, so it can help with local SEO. So, it’s important to make sure you have claimed your listing, which gives you the ability to write or respond to reviews.
Run A Google Review Email Campaign
When you are wanting to do a local SEO search, you want to have good Google Reviews, as many people will be leaving reviews on this section. So, this is also incredibly important from an SEO perspective.
The SEC staff said if you have an objective policy to remove slanderous and hateful posts, then you can absolutely delete them from your professional site, such as Google My Business. It won’t consider the site to be considered an advertisement, you aren’t adopting any of the reviews. Except, the more you start using the GMB, the more you start responding and liking comments then it does bring up the more “advertising” side of the rule. So, you need to be careful in how deep you are going to go, but you can definitely remove a negative comment if it is not truthful.
What if it is truthful, but you don’t agree? Do you have the authority to go ahead and respond and share your side of the story?
Yes, you certainly can respond but once you respond, then you’re “entangled” in the communication, then the whole communication back and forth will be considered advertising.
What are the “Ins” and “Outs” in asking people for a review?
In the future, this could be “fair-game” but right now, it’s a bit ambiguous, but the problem of doing this on day one is a bit of a risk. The approach to contacting your clients is fairly biased, so could this create some sort of misleading inference?
Include A Link In Your Email Signature And a CTA On Your Website
This should be fine and hasn’t seen it raised during an observation, nor does the SEC view this as a misleading practice
Google Reviews Landing Page + Link Out To Review Page
A lot of states reference the “Advisors act” as their “law” but for the states that have not formally adopted the Advisors’Act as the standard and get comfortable with whatever stage they are a part of.
Bigger broker-dealers don’t let advisors change or manage their own Google My Business page. Do you think this will change?
It’s hard to say, however, this should be “loosening” up a bit in the future. When it comes to social media, the more “entangled” you become with comments, then it starts to become more of an advertisement.
2. Social Media [22:59]
- Proactively connect with your clients
- If a client leaves a comment, you can now respond
- Share testimonials (screenshots) of public reviews
So, when it comes to “cherry-picking’ you can’t just show one favorable review. You need to do more to show that not every one of your reviews is glowing. You don’t have to include a negative review with every positive review, but you need to provide some type of disclaimer or provide a link so that visitors can go see all of the reviews.
From a marketing standpoint, there is a big difference in sharing what people have said to you, like a screenshot of it, versus a screenshot of it. You want to share your reviews “as-is” rather than rewriting them yourself. There is a fine line between sharing good news and bragging, so it’s a good idea to try to tie the review back to someone else.
Under the new rule, they start looking at testimonials, so they need to comply with the other rules. You need to be cognizant of how you compensate people for testimonials, and then once you decide you are going to go this route, it’s pretty straightforward.
What is the Difference Between a Review and a Testimonial?
If there is a social media platform with favorable reviews, and you aren’t interacting except for deleting “false” content…those aren’t going to be endorsements. It becomes an endorsement when you take something that was said favorably and then you adopt it, send it out, put it on your website, etc.
3. Client Videos [32:06]
- Choose clients who will connect with your target audience
- Ditch the script and be authentic
- Address pain points when creating videos for your clients and prospects
If someone leaves you a review organically, you don’t have to respond to it. If you are going to ask someone to participate, then you need to be more proactive and add disclosure of where people can find all the reviews. You can not do anything and be compliant.
On LinkedIn, someone can endorse you as well. Does this rule change the ability to be endorsed on LinkedIn?
He thinks it will open up the avenues a bit, but he images that smaller firms will open it up and let advisors use endorsements to get reviews on their LinkedIn profiles.
Can you ask clients to like or follow on social media?
This should be fine, as should the invitations to Facebook asking for a “like.”
4. Testimonials + Your Website [40:09]
- A dedicated page with videos & quotes
- Blog posts
- Exit-intent popups
The same concerns that we have addressed with video, are the same issues with adding testimonials to your website. You need to make sure you are working through everything and making sure you are doing everything with that portion of the rule. Does it create any sort of unfair inference? If the reviews came from an email to the client, it definitely lessens the obligation for disclosure unless you’ve got a similar negative email, then you have to figure out how you do this with the rule.
For example, if you have ten positive reviews, then you can take some screenshots of some of them and then include a link to show all of the reviews. This is easier from a compliance standpoint because it will all be there.
Adding Feature To Scroll Through Google Reviews On The Site
You need to be careful with how you do it and if you are being compliant, and we are building pages where you can add in Google Reviews, so we will make it very easy to add this to your Twenty Over Ten or FMG Suite websites.
For more information and tips on how to do this, you can register for FMG Suite’s webinar to find out more about how to leverage the power of client testimonials and reviews.
From a marketing perspective, what if you want to take these and put them on a PowerPoint slide? Can you include the Google Reviews on those slides?
Whether it’s your website, collateral, a PowerPoint deck, the rules are going to be the same with how you go about doing that. If it’s a favorable review from a client, you need to do it in a way that is thoughtful and does not violate the 7 Prohibitions. The hyperlink is going to be the easiest way to provide the additional reviews, so it’s very doable.
5. Repurpose Reviews [45:10]
- Case Studies
- Blog Posts
Max’s blog can provide you with more rules and information in terms of repurposing your reviews.
If you don’t have a Trustpilot account, you can go in search of your company, claim it and make it so that it is yours, which will give you more ability to respond to reviews. You will be notified when a review is left, if you want to respond, etc,
There’s an entanglement conception, then the more involved you are, the more entangled you are with it. So, whatever gets posted is your advertisement. So, if the client leaves some misleading review, then you are going to have to own that.
The new rule has a very specific requirement for performance advertising, so go look at the rule and see what it has to say. What are the time periods that you have to show your performance? There are a lot of requirements if you are going to do performance advertising before you get a grasp on it.
If someone leaves a comment saying something really nice versus if someone sends you an email, would you treat them separately as far as permission goes?
Safely, you have a lot of privacy policies and are mostly fiduciaries, so it is best practice to get permission from every single client before you use their personal information online. Legally, you are free to use it if it’s in the public domain, such as LinkedIn, but it’s a good idea to get permission.
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About the author
Blair is a digital marketing assistant at Twenty Over Ten and has a passion for uncovering what drives online traffic and the highest engagement. She follows more animals on Instagram than humans and her greatest achievement is her daughter, Grey.