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III. Advertising Representations to Clients
The Advisers Act prohibits advisers from making misleading statements or omitting material facts in connection with conducting an investment advisory business.12 The following are examples of false advertising or other misrepresentations to clients found during examinations:
- The use of testimonials, which include any statement of a client's experience with the adviser or a client's endorsement of the adviser. Testimonials are prohibited under the Advisers Act.13
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