Best Investors
Sign in
Best Investors
Sign in
Form ADV Part 1A Item 5L(1)(d) · Answer type: yn · Item 5 - Advertising
Item 5L(1)(d) asks whether any of the firm's advertisements include endorsements - meaning promotional statements or recommendations from people who are not current clients of the adviser, used in marketing materials.
Under SEC marketing rules, an endorsement is any statement by a non-client that promotes the adviser's services, recommends the firm to others, describes positive interactions with the adviser, or vouches for the adviser's capabilities. This includes statements from business partners, industry professionals, media personalities, social media influencers, referral sources, or other third parties who endorse the firm's services.
Endorsements can appear as written quotes, video testimonials, recorded interviews, social media posts, or any promotional content from someone who has not been a client. They might include statements from other professionals like "I refer my clients to this firm," comments from industry experts, or promotional content from business affiliates.
A firm featuring quotes from referring attorneys, having industry experts recommend their services in marketing materials, or promoting endorsements from business partners would mark Yes. A firm that only uses their own content or client testimonials would mark No.
This checkbox excludes endorsements that satisfy a narrow SEC rule exception for certain qualified statements, but most promotional endorsements from non-clients count toward a Yes answer.
Yes
The adviser uses statements, quotes, or recommendations from non-clients in their advertising materials. Under SEC rules, endorsements often involve compensation or business relationships that must be disclosed, and endorsements must include required disclaimers about the endorser's qualifications and any conflicts of interest.
No
The firm does not use endorsements from non-clients in advertisements on this checkbox. Their marketing may include client testimonials, performance data, or third-party ratings, but does not feature promotional statements from people who have not been clients.
5L(1)(d) - Do any of your advertisements include endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii)) (Yes / No).
This checkbox is part of Item 5L, which covers advertising practices under SEC marketing rule requirements. The rule exception referenced covers certain qualified endorsements with specific disclosure requirements.
Endorsements from non-clients can influence your perception of a firm, but the endorsers may have financial relationships or other conflicts that affect their statements. A Yes answer means you should understand who is endorsing the firm and why.
When firms use endorsements, SEC rules typically require disclosure of any compensation paid to endorsers, business relationships between the firm and endorser, and the endorser's qualifications to make the statements. However, endorsements are selected and promoted by the firm and may not reflect independent, unbiased opinions.
A Yes does not tell you who the endorsers are, whether they are compensated, what their relationship to the firm is, what their qualifications are, or whether they have conflicts of interest. It also does not indicate whether the endorsements represent typical professional opinions about the firm.
Use 5L(1)(d) as a prompt to ask about the identity and qualifications of endorsers, whether they are compensated or have business relationships with the firm, and what disclosures accompany the endorsements.
Yes
The firm reports using endorsements from non-clients in advertisements. On the firm's Best Investors ADV panel, check 5L(2) to see if they pay compensation for testimonials, endorsements, or ratings. Also review Items 8H and 8I about referral compensation, which may connect to endorsement arrangements.
If you are considering this firm, ask to see their actual endorsements with any required disclosures, inquire about the endorsers' relationships to the firm and any compensation involved, and verify the endorsers' qualifications to make their statements.
No
The firm does not report using endorsements from non-clients on this checkbox. They may still use other marketing approaches like client testimonials (5L(1)(c)), performance results (5L(1)(a)), or third-party ratings (5L(1)(e)). Review these related 5L rows to understand their complete advertising strategy.
Look at the firm's business activities in Item 6 and affiliations in Item 7 to understand their professional relationships, which could provide context for potential endorsement sources not captured on this line.