NASAA Model Rule

NASAA Marketing Rule

The NASAA Model Rule on Advertising and Marketing establishes standards for how state-registered investment advisors can promote their services, present performance data, use testimonials and endorsements, and communicate with the public.

Key Requirements

Fair and Balanced Advertising

All advertising must be fair, balanced, and not misleading. Advisors must ensure that marketing materials do not contain untrue statements of material fact or omit information necessary to make statements not misleading.

Performance Presentation Standards

Net-of-fees performance must be shown alongside any gross performance. Time periods must be clearly disclosed, and hypothetical or backtested performance requires prominent disclaimers.

Testimonial and Endorsement Disclosures

Testimonials and endorsements must include disclosures about compensation, conflicts of interest, and whether the person providing the testimonial is a client of the advisor.

Third-Party Rating Disclosures

When displaying third-party ratings or rankings, advisors must disclose the date, criteria, and the identity of the rating organization, along with any compensation provided.

Social Media Compliance

Social media posts are considered advertising and must comply with all marketing rule requirements. Advisors must maintain records of all social media communications.

Books and Records for Advertisements

Copies of all advertisements must be retained for at least five years, including drafts and internal review documentation.

State Adoption Status

Proposed — TX adopted by reference to SEC rules (eff. March 2025)

Adoption of NASAA model rules varies by state. Some states adopt the model rule directly, while others have their own rules covering the same requirements.

Visit the State Adoption Tracker for a complete per-state breakdown. Data sourced from NASAA model rule matrix and NV 2024 Legislative Survey. Last verified March 2026.

Common Violations

Avoid these frequently cited deficiencies during state examinations.

Misleading Performance Claims

Presenting cherry-picked time periods, showing gross performance without net, or failing to disclose benchmark comparisons.

Inadequate Testimonial Disclosures

Using client testimonials without proper compensation disclosures or conflict of interest statements.

Unsubstantiated Claims

Making claims about expertise, rankings, or results without adequate documentation to support them.

Missing Social Media Records

Failing to archive and retain records of social media posts and interactions related to advisory services.

Best Practices

Establish a pre-publication review process for all marketing materials
Maintain a centralized archive of all advertisements and communications
Use standardized performance presentation templates with required disclosures
Train all staff on social media compliance requirements
Conduct quarterly reviews of advertising materials for compliance
Document the review and approval process for each piece of marketing material

Frequently Asked Questions

Ready to transform your compliance workflow?

Be among the first to experience AI-powered compliance technology.