SEC’s Modernized Marketing Rule Testimonial Support Now Available
This feature is off by default and must be enabled and configured by an admin.
The SEC has implemented new rules that require advisors/agents to respond equally and appropriately to all testimonials they receive. To mitigate risk of non-compliance to the SEC’s rule, we created an automated solution that varies based on whether the testimonial was left on Facebook or LinkedIn.
Under Facebook’s New Page Experience, advisors/agents must either respond to all reviews or completely ignore all reviews in order stay compliant with the SEC rule. Hearsay’s solution is to automatically reply to every review, with language provided by a setting controlled by admins, that either accepts or disavows the review. Reviews can be turned off completely from the advisor/agent's native Facebook page.
LinkedIn Recommendations can be hidden after they are accepted, which allows Compliance to hide recommendations that violate their individual policies.
Advisor/agent Workflow for Testimonials
When someone leaves a testimonial, the advisor/agent receives an email asking them to identify the individual who wrote it, and gives the timeframe for them to take action.
If they select Provide additional info, they are taken to this screen to provide the information.
If the advisor/agent doesn’t provide the information on time, they are informed that the testimonial is disavowed.
Enable and configure the feature
You must configure these settings to use this feature.
In the Administrative view, click Settings > Organizational Settings > Review & Archive. Under Testimonial Review, configure these settings:
SEC Regulated
- Enabled: Testimonials left for advisors/agents are subject to these settings.
- Disabled: Ignore all testimonial checks and treat testimonials as they were before (same as a post or comment).
Testimonials allowed (LinkedIn only)
- Enabled: If yes, then following settings are used.
- Disabled: Testimonials are not allowed on LinkedIn and they will be hidden.
Classification Time Limit (in hours)
- Advisor/agent must respond to a testimonial within this time period or it is automatically disavowed. Can be set from 12 to 168 hours.
Alert on All Testimonials
- Enabled: Compliance must accept or reject every incoming testimonial.
- Disabled: Compliance accepts all testimonials that do not flag lexicon, and receives alerts on those that do flag.
Allow Solicited Testimonials
- Enabled: Testimonials won’t be automatically disavowed if marked as solicited.
- Disabled: Testimonials marked as solicited will be disavowed and trigger a compliance review.
Allow Non-Client Testimonials
- Enabled: Testimonials won’t be automatically disavowed if sent by a non-client.
- Disabled: Testimonials from a non-client will be disavowed and trigger a compliance review.
Allow Conflict-of-Interest Testimonials
- Enabled: Testimonials won’t be automatically disavowed if a conflict-of-interest exists.
- Disabled: Testimonials that involve a conflict-of-interest will be disavowed and trigger a compliance review.
Accepted Testimonial Language (Facebook only)
- Statement on accepted testimonials, up to 520 characters.
Rejected Testimonial Language (Facebook only)
- Statement on disavowed testimonials, up to 520 characters.
New Supervision Items
You can find testimonials that are prohibited based on your settings in the supervision queue by selecting the Review Type > Prohibited Review filter.
Supervision options:
- Accept: Keep the testimonial (LinkedIn) or leave a comment with acceptance language (Facebook).
- Reject: Remove the testimonial (LinkedIn) or leave a comment with disavowed language (Facebook).
- Reject & Block: Leave a comment with disavowed language and block the user from posting on that page (Facebook only).