Google and Yelp are well-known review platforms popular with consumers. And many advisors already have unsolicited reviews written about them visible on these sites. If these are favorable reviews and are truly unsolicited, that’s terrific as advisors gain SEO benefits and visibility among consumers visiting these sites.

However, because reviews on Google and Yelp lack the required SEC disclosures to be considered advertisements (e.g., testimonials and endorsements you can promote to grow your business), advisors can’t direct prospects to check out their reviews on these platforms. 

Advisors should think twice before using Google to collect reviews. Here are a few reasons why:

• It is unlikely Google will modify its platform to make Google Reviews compliant if the SEC deems a review to be an advertisement.
• When advisors ask clients to leave a review on Google, it may be deemed an advertisement by the SEC, according to securities industry attorney Max Schatzow. If this occurs, advisors will be in violation of the SEC rule as Google is not designed to comply with SEC disclosure requirements.
• We continue to hear from leaders of advisory firms who invited their clients to write reviews on Google, and some of their reviews discuss investment performance. This situation isn’t hypothetical. Advisory firms with the best of intentions realize their Google Business Profiles are now toxic, containing reviews with promissory language and content prohibited by the SEC Marketing Rule.
• While the SEC will let advisors compensate clients for a review, Google prohibits the practice.
• Requesting the removal of Bad Actors as defined by the SEC will require filing a legal violation, which can take time and effort.

Here’s What We Don’t (Yet) Know:

Unlike unsolicited reviews published on Google or Yelp, the SEC has not formally offered guidance to clarify if solicited reviews on Google and Yelp are deemed an advertisement and, therefore, subject to the prohibitions and disclosure requirements described in the SEC Marketing rule. So the question we need the SEC to answer is: Does the act of a financial advisor simply asking for a review to be written on specific platforms like Google or Yelp entangle an advisor in its creation and trigger the prohibitions and disclosure requirements?

While industry opinions are mixed on the guidance the SEC will ultimately provide, we believe it’s highly likely the SEC will take issue with advisors proactively soliciting reviews on platforms known to be incompatible with the Marketing rule. With its principles-based rule intended to ensure consumers gain important information to make more informed decisions, we don’t expect the SEC to look favorably upon a rampant proliferation of advisor reviews on platforms incapable of addressing the Marketing rule’s prohibitions and disclosure expectations.

We continue to hear from leaders of advisory firms who invited their clients to write reviews on Google, and some of their reviews discuss investment performance. This situation isn’t hypothetical. Advisory firms with the best of intentions realize their Google Business Profiles are now toxic, containing reviews with promissory language and content prohibited by the SEC Marketing Rule.

Further, we believe the SEC could point to FINRA Regulatory Notice 17-18, which addresses this topic covering testimonials of registered representatives. In the notice, FINRA states: “FINRA does not regard unsolicited third-party opinions or comments posted on a social network to be communications of the broker-dealer or the representative for purposes of Rule 2210, including the requirements related to testimonials in paragraph (d)(6).”  

Wealthtender has submitted written requests for clarification on this matter to the SEC (likely along with many other industry participants) and we monitor the SEC’s Marketing rule FAQ page daily. We’ll share updates as additional SEC guidance becomes known.

October 12, 2021 Update: The SEC Investment Adviser Regulation Office (within the Division of Investment Management) responded by email to Wealthtender confirming their team will consider updating the SEC Marketing rule FAQ page to address the analogous question answered by FINRA in Regulatory Notice 17-18 that could put this matter to rest.

September 3, 2023 Update: Unfortunately, nearly two years later, the SEC still hasn’t chimed in. 🤷‍♂️

As a financial advisor, it’s important to understand how the new SEC Marketing rule could affect you and your advisory business. Even if you don’t plan to ask for reviews or include reviews in your own marketing activities, you’ll need to be prepared to respond to questions from prospects and existing clients when they begin to see reviews appear online for other financial advisors.

While online reviews may be new to financial advisors, an evaluation of their impact on local businesses and  professionals in other industries demonstrates why it’s imperative to begin preparing for a future where consumers are empowered to voice their opinions about you and your services.

The importance of online reviews on local businesses can be seen in numerous research reports conducted each year. 

In an annual report prepared by BrightLocal based on a survey conducted in November 2020, 87% of consumers said they read online reviews for local businesses in 2020, up from 67% in 2010. The report indicated after reading a positive review for a local business, the next most likely actions are visiting the website of the business, searching for additional reviews to validate their choice and visiting the business in person.

And according to a research survey conducted in October 2020 by SurveyMonkey Audiences commissioned by Podium, among the 1,543 consumers surveyed, 88% said online reviews played a role in discovering a local business, 65% have read an online review in the last week and 41% said online reviews are 1 of the 3 most important factors they consider when choosing a local business.

Financial advisors interested in growing their practice should take note of these additional findings:

• 85% said employee attitude is the leading motivation to leave a positive review
• 58% of consumers said they would be willing to travel farther to a business with better reviews
• 47% are willing to pay more at a business with higher reviews
• Over 60% of consumers said they are likely to leave a review after a good experience with a local business when the business follows up with a link in an email asking for a review

As Emmy-winning writer David Pogue wrote about online review sites in Scientific American nearly 10 years ago, “No longer are you on top of the mountain, blasting your marketing message down to the masses through your megaphone. All of a sudden, the masses are conversing with one another. If your service or product isn’t any good, they’ll out you.”

Wealthtender is the first independent financial advisor review platform designed to be fully-compliant with SEC regulations.

The SEC marketing rule served as the blueprint for building the Wealthtender review platform. Financial advisors can confidently collect and display reviews on their Wealthtender profile page with the required disclosures clearly and prominently displayed as prescribed by the SEC.

Unlike other review platforms, Wealthtender incorporates workflows for financial advisors to provide required disclosures which may be unique for each individual review. This ensures advisors can rest easy during SEC exams and sweeps when asked how reviews are used in their marketing activities.

To learn more about how Wealthtender compares to Google Reviews and other potential financial advisor review platforms, click here.

Will online reviews of financial advisors impact how prominently a financial advisor and their website appears in Google search results?

Very likely, the answer is yes, thanks to E-A-T and YMYL.

E-A-T And YMYL 

E-A-T is a term used by Google that stands for Expertise, Authoritativeness and Trustworthiness as it pertains to the creator of website content. The term originates from a 175-page document used by human ‘Quality Raters’ to assess the quality of Google’s search results. 

YMYL is another term defined by Google in the document as topics that could impact ‘Your Money or Your Life’. Specifically, Google states that “Some types of [web] pages or topics could potentially impact a person’s future happiness, health, financial stability, or safety. We call such pages “Your Money or Your Life” pages, or YMYL.”

Financial advisor websites are already subject to higher E-A-T and YMYL standards by Google than websites on topics of less importance to people’s lives. 

When online reviews of financial advisors proliferate, Google’s guidelines for Quality Raters hint at the importance they’ll place on third party reviews over client reviews found directly on a financial advisor’s website. Specifically, Google states “you must also look for outside, independent reputation information about the website. When the website says one thing about itself, but reputable external sources disagree with what the website says, trust the external sources.”

By joining Wealthtender, financial advisors increase their E-A-T scores in the eyes of Google, strengthening their online reputation and improving their ranking in online search results.

For doctors and lawyers, online reviews have simply become a fact of life and requirement for conducting business. For financial advisors preparing for the new Investment Adviser Marketing rule, it’s worth considering insights gained about the role of online reviews across both professions.

What Financial Advisors Can Learn About Online Reviews From Doctors And Lawyers

With millions of reviews of doctors and lawyers, these sites often rank on the first page of Google results when consumers search for these professionals. In the BrightLocal consumer review survey, 89% of consumers said they look at reviews of medical professionals and 81% look at lawyer reviews. Over 80% of consumers said they believe reviews are important across both categories of professionals. 

In 2018, an NRC Health Market Insights Study of over 3,000 patients showed that 37% used online reviews as their very first step in searching for a new doctor. And even when getting a recommendation from someone they trust, 21% then turned to online reviews to verify what they were told. 

Additional findings included:

• 83% said they trust online ratings and reviews more than personal recommendations
• 48% trust online ratings and reviews as much as a recommendation from their doctor
• 75% want to see at least 7 ratings before they trust a doctor
• 66% consider reviews older than 18 months to be out of date
• 59% said positive and negative reviews are equally valuable to them
• 60% said they’re suspicious if they only see positive reviews for a doctor 

In 2018, a Martindale-Avvo survey of 6,300 consumers asked the criteria that mattered most to them when choosing an attorney. When asked what information they desired before their first contact with an attorney, online reviews or client testimonials ranked 5th among 20 factors. The survey also noted consumers aged 25-35 gave greater weight to reviews and testimonials than consumers over age 54.

Additional consumer findings included:

• 47% used online review sites and directories to find an attorney (more than any other resource)
• 46% read online reviews of an attorney to conduct additional research after a personal referral

As Meranda Vieyra eloquently stated in The National Law Review, “The great thing about online reviews is that you have power to present your law firm and yourself with dignity and class, regardless of how good or bad your online reviews are.” For financial advisors preparing for the Investment Adviser Marketing rule, these words may prove prescient.    

Q: What is the effective date of the SEC Investment Adviser Marketing rule?

A: The SEC Investment Adviser Marketing rule became effective on May 4, 2021, 60 days after it was published in the Federal Register.

Q: What is the compliance deadline for the SEC Investment Adviser Marketing rule?

A: The compliance deadline for the SEC Investment Adviser Marketing rule is November 4, 2022, eighteen months after the May 4, 2021 effective date. (Source: Federal Register)

Q: What are SEC expectations for advisor reviews under the new rule?

A: Financial advisors who choose to include client reviews in their advertising under the new rule will need to work closely with their compliance officers to ensure they satisfy the SEC’s new disclosure and oversight requirements.

Key SEC expectations for advertisements featuring financial advisor reviews include:

– Clear and prominent disclosure indicating: If a review is from a client or non-client
– Whether or not the reviewer was compensated
– How the reviewer was compensated (in cash or otherwise)
– Any conflicts of interest (including a description of conflicts)
– A written agreement must be in place between a financial advisor and reviewer (unless the reviewer receives less than $1,000 for their review in cash or otherwise within a 12 month period)

The SEC also made it clear these requirements apply even if the review is a social media post like a tweet with a limited number of characters.

Q: Why can’t I find more financial advisor reviews on Yelp?

A: Since it’s a violation of Yelp’s terms of service for businesses to ‘solicit or ask for reviews’ from their customers, financial advisors are unable to encourage their clients to write a review on Yelp.

Q: Can financial advisors have Google Reviews?

A: Google and Yelp are well-known review platforms popular with consumers. And many advisors already have unsolicited reviews written about them visible on these sites. If these are favorable reviews and are truly unsolicited, that’s terrific as advisors gain SEO benefits and visibility among consumers visiting these sites.

But because reviews on Google and Yelp lack the required SEC disclosures to be considered advertisements (e.g. testimonials and endorsements you can promote to grow your business), advisors can’t direct prospects to check out their reviews on these platforms.