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Marketing Rule Policy Template for Investment Advisers

Advisers Act Rule 206(4)-1

What counts as an advertisement, how performance may be shown, when testimonials and endorsements are allowed, and how material is reviewed and approved before it goes out.

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What the rule requires

The Marketing Rule prohibits seven kinds of statement in any advertisement, including untrue statements, unsubstantiated material facts and presentations that are not fair and balanced. It sets specific conditions for performance: net alongside gross, prescribed time periods, and policies for extracted, hypothetical and predecessor performance.

Testimonials and endorsements need clear disclosures and oversight, and most paid promoters need a written agreement. Third-party ratings have their own conditions. Rule 204-2 requires copies of advertisements and the records that substantiate them, and Form ADV asks about marketing practices.

What the policy covers

The sections of Luna's model Marketing and Advertising policy. Your draft includes only the clauses that apply to your firm.

  1. 1Purpose, scope and applicability
  2. 2What counts as an advertisement
  3. 3General prohibitions (all advertisements)
  4. 4Performance
  5. 5Testimonials and endorsements
  6. 6Promoters and solicitation arrangements
  7. 7Third-party ratings
  8. 8Review and approval
  9. 9Social media, websites and electronic communications
  10. 10Private fund offerings
  11. 11Records, Form ADV and oversight

What Luna asks you

A few of the questions that shape the draft:

  • Who approves marketing material, and who submits it
  • Whether the firm permits testimonials and endorsements
  • Which social media platforms are approved for business use
  • How the firm's private funds are offered

How drafting works

  1. 01
    Answer questions about your firm

    Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.

  2. 02
    Luna drafts the policy

    Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.

  3. 03
    Review what is left

    Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.

  4. 04
    Edit, approve and roll out

    It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.

Read the source

Other policies

A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.