Marketing Strategy

Marketing for New Financial Advisors: The No-Fluff Playbook to Get Your First Clients

By Oliwer Jonsson, Founder of OJay Media

Struggling to get clients in year 1-3? This guide covers marketing for new financial advisors — budgets, channels, niches, and a 12-month roadmap.

Oliwer Jonsson Oliwer Jonsson, Founder of OJay Media
22 min read

Most new advisors spend their first year doing everything their training told them to do — calling warm contacts, attending Chamber of Commerce lunches, asking family for referrals — and still sitting at $8M AUM twelve months later wondering if they made a mistake.

They didn't make a mistake switching careers. They made a mistake trusting a prospecting model built for 1997.

The traditional "build your book through your natural market" approach worked when there were fewer advisors, fewer choices, and no internet. Today a prospect can find 40 advisors on Google in four minutes, compare your fees on a third-party site, and read your FINRA BrokerCheck record before you've finished dialing their number.

Marketing for new financial advisors in 2024-2026 requires a different playbook — one built around positioning, digital visibility, and a realistic understanding of what your budget can actually buy.

This guide gives you that playbook.


Key Takeaways


How Do New Financial Advisors Get Clients?

New financial advisors get clients through a combination of referrals, professional networking (Centers of Influence), and digital visibility built around a specific niche. In the first 12 months, the most effective channels are personal outreach to warm contacts, LinkedIn organic content targeting a defined prospect profile, and COI relationships with CPAs, estate attorneys, and HR benefit managers. These channels cost time, not money, and they compound. A single CPA relationship that sends two referrals per quarter is worth more than a $2,000/month ad campaign at a sub-$25M AUM book size. Once the advisor reaches $15-25M AUM and has a proven conversion process, paid channels — specifically Meta retargeting and hyper-local Google Search — become worth testing. The sequence matters: referral infrastructure first, digital presence second, paid amplification third.


The New-Advisor Reality: Why Most Don't Make It Past Year 3

The attrition numbers are worth stating plainly. According to industry research cited by Kitces and LIMRA, approximately 80-90% of new financial advisors leave the profession within five years. Most of those exits happen in years 1-3. The survivors share one trait more than any other: they found a repeatable way to get in front of qualified prospects before their training allowance ran out.

The failure is almost never about knowledge of financial planning. It's about pipeline.

The pipeline math for a new advisor looks like this:

Most advisors are not doing 15 prospect touches per week. They're doing 3-5, and they're doing them inconsistently, and they're targeting people who cannot afford them or who are already working with someone else.

Why the traditional "natural market" model fails new advisors:

The natural market — friends, family, former colleagues — has two problems for most new advisors. First, the AUM tends to be too low. A 32-year-old advisor's peer group probably has $50K to $200K in investable assets. Second, the trust transfer does not work the way training materials suggest. People are willing to buy a product from a friend. They are far more reluctant to hand over their retirement account.

The advisors who survived year 1-3 and built books worth keeping were not better at "dialing for dollars." They picked a niche, built authority in that niche faster than their competition, and created a system that generated inbound interest rather than relying solely on outbound activity.


Foundation Before Marketing: Niche, ICP, and Positioning

Before spending a dollar or an hour on marketing, a new advisor must answer one question: who do I serve, and why should they choose me over the 10 other advisors in my market?

Positioning is not a marketing tactic. It is the structural decision that makes every other marketing decision easier or harder. An advisor who says "I help anyone with money" will struggle to write a LinkedIn post, a Google ad, or a referral script — because nothing they write will feel relevant to any specific reader.

An advisor who says "I help federal employees in Virginia understand their FERS pension, TSP, and survivor benefit options" can write a LinkedIn post that makes a GS-13 employee in Reston say "this person understands my situation."

Which niche is right for you?

The best niche is at the intersection of three things: a population large enough to build a $100M+ AUM business, a problem complex enough to require advice (not just products), and some authentic connection you have to that group — either through background, shared experience, or deep knowledge.

The table below compares five of the most viable niches for a new advisor in 2024-2026:

Niche Avg. Investable Assets Competition Level Why It Works for New Advisors Main Challenge
HENRYs (High Earners Not Rich Yet — $150K-$400K income, 30s-40s) $100K-$500K High in cities Large population, complex tax/RSU/student loan needs, willing to pay for clarity Low AUM per client at first; need volume
Business Owners / Small Business Sellers $500K-$3M+ Moderate High AUM, high-complexity, great COI referral sources (CPAs, M&A attorneys) Long relationship build; complex planning
Physicians / Dentists $300K-$2M High High income, student debt complexity, malpractice planning needs, group referrals Skeptical buyers; need credential credibility
Women in Transition (divorce, widowhood, inheritance) $200K-$1M+ Low-Moderate Underserved, high trust when earned, word-of-mouth referral rates high Emotional complexity; longer sales cycle
Federal Employees (FERS, TSP, FEGLI) $200K-$600K Low Almost no specialist advisors, high rule complexity, geographic clustering Policy knowledge requirement; niche content volume

None of these niches is wrong. All of them are better than "everyone." Pick the one where you can build the fastest authority and where the COI relationships are most accessible from where you sit today.

Once you have a niche, build your Ideal Client Profile (ICP): a one-page document that describes the specific person — their age range, income, job title, financial complexity, and what they typed into Google before finding you. Every piece of content you produce should speak to that person.

For deeper guidance on building a positioning foundation, see marketing plan for financial advisors and financial advisor marketing ideas.


The New-Advisor Marketing Budget Reality

One of the most common mistakes new advisors make is trying to scale paid advertising before they have a proven offer and a conversion process. Running $5,000/month in Google Ads before you know how to close a discovery call is expensive market research.

The table below shows what is realistic at each budget tier, based on what we see working across our advisor client portfolio at OJay Media:

Monthly Budget Best Channels Expected Outcome What Not to Do
$0 (time only) LinkedIn organic, referral outreach, COI meetings, free local seminars 2-5 new conversations/month if consistent Do not try to do everything; pick one channel and build depth
$500/mo LinkedIn organic + basic CRM ($50-80/mo) + one local event sponsorship 3-6 conversations/month; starts building brand data Do not spend on paid ads — budget too thin to optimize
$2,000/mo LinkedIn organic + Meta retargeting ($800-1,000) + basic SEO content ($500) + CRM 5-10 conversations/month; retargeting builds warm audience Do not buy SmartAsset/Zoe leads at this budget — CPL too high relative to conversions
$5,000/mo Meta retargeting + narrow LinkedIn ads + local Google Search ($1,500) + content production 10-20+ conversations/month; first scalable paid pipeline Do not try to go national; keep geo-targeting tight to your market

The math on lead generation platforms deserves a specific note. Third-party lead platforms (SmartAsset, Zoe, WiserAdvisor) sell shared leads — the same prospect goes to 3-5 advisors simultaneously. For a new advisor without brand recognition, closing a shared lead at a cost of $200-$600 per lead is a steep hill. Those platforms work better at $50M+ AUM when your brand and retention rate justify the cost.

For a detailed breakdown of where advisory marketing budgets go, see financial advisor marketing budget and financial advisor marketing cost.


Free and Low-Cost Marketing Channels for New Advisors

Referrals: Still the Highest-Converting Channel

The advisor industry's average referral rate is roughly 2-3 referrals per 10 clients per year, according to research published by Kitces.com. The advisors who build niche practices with strong emotional resonance see rates of 5-8 per 10 clients.

Referrals do not happen automatically. They happen when three conditions are met: the client had a specific, memorable experience worth talking about; they know exactly who to refer you to; and you made it easy for them to make the introduction.

Build a referral system, not a referral hope. That means a 90-day client onboarding sequence with at least one "wow" touchpoint, a clear ask ("If you know another federal employee approaching retirement who has questions about their FERS pension, I'd love an introduction"), and a follow-up thank-you when a referral comes through.

Centers of Influence (COI) Building

A single CPA firm that sends you two referrals per quarter will do more for your practice than six months of cold outreach. The same applies to estate attorneys, HR benefit managers, employee benefits brokers, and divorce attorneys (if you serve women in transition).

COI strategy for new advisors:

  1. Identify 10-15 professionals in your market who serve your niche
  2. Book a no-ask coffee meeting — your goal is to understand their practice, not pitch yours
  3. Bring value first: share a piece of content they can use with their clients, introduce them to someone in your network, or solve a client problem together
  4. After 2-3 value-first interactions, propose a formal referral arrangement or at minimum a mutual introduction process

COI relationships take 3-6 months to produce referrals. Start them on day one.

LinkedIn Organic for Financial Advisors

LinkedIn is the highest-leverage free channel for most financial advisor niches because your ideal clients and COI partners are already there. The platform rewards consistency and specificity over production value.

A content system that works for new advisors at zero cost:

Results from LinkedIn organic typically start appearing at months 3-4 and compound through month 12. Do not quit at month 2.

For a tactical breakdown of the LinkedIn approach, see linkedin for financial advisors.

Content Marketing and SEO

Writing articles or recording short videos that answer the specific questions your niche is Googling creates durable inbound traffic. A federal employee advisor who writes 20 articles about FERS pension optimization, TSP withdrawal strategies, and FEGLI coverage will eventually rank for searches that bring prospects directly to their site.

SEO takes 6-12 months to generate meaningful traffic for a new site. The advisors who start it in month 1 are the ones seeing inbound leads in month 9.

For a full prospecting system breakdown, see financial advisor prospecting strategies.

Free Seminars and Workshops

A 60-minute workshop on "What Federal Employees Need to Know About Their FERS Pension Before Retiring" delivered at a federal agency building or public library costs you two hours and zero dollars. Done well, it produces 3-5 discovery calls per event.

The keys: target a venue where your niche congregates, promote 3 weeks in advance via LinkedIn and email, collect contact information at registration, and follow up within 24 hours.

Podcast Guesting

Being a guest on a podcast your prospects listen to is one of the fastest ways to build trust with cold audiences. A 45-minute interview where you demonstrate expertise creates a "long-form trust asset" that a prospect can listen to during their commute. A single podcast appearance that reaches 2,000 listeners in your niche can generate more pipeline than three months of LinkedIn posts.

Find podcasts in your niche (search "[niche] podcast" on Apple Podcasts or Spotify), listen to three episodes, and send a personalized pitch explaining what your segment would give their audience.


Meta Retargeting (Facebook and Instagram)

Broad prospecting on Meta — showing ads to cold audiences — is expensive and competitive for financial advisors. Most new advisors do not have the budget to win that game.

Retargeting is different. When someone visits your website or watches 50% of a LinkedIn video, they have already signaled interest. A Meta retargeting campaign that follows those warm visitors with a specific offer ("Book a Free 30-Minute FERS Pension Review") converts at 3-8x the rate of cold traffic. At a budget of $600-$1,000/month, retargeting keeps you in front of warm prospects until they are ready to book.

Minimum viable setup: Meta Pixel installed on your website, retargeting audience of 500+ website visitors (takes 4-8 weeks of organic traffic to build), one clear offer with a landing page that loads fast on mobile.

Narrow LinkedIn Ads

LinkedIn's targeting allows you to reach specific job titles at specific companies — a degree of precision no other platform matches. An advisor targeting physicians can target "Physician" and "MD" job titles within 25 miles of their office. An advisor targeting federal employees can target government agency employers.

The floor for LinkedIn ads is roughly $1,500/month to generate meaningful impressions. Below that, the algorithm does not have enough spend to optimize. The format that performs best for new advisors is a lead generation form ad with a low-friction offer ("Download our Federal Employee Retirement Checklist").

Hyper-Local Google Search Ads

Someone who types "financial advisor for doctors in Atlanta" into Google is looking to hire an advisor. Google Search captures that intent at the moment it exists. For a new advisor with a specific niche, a hyper-local Google Search campaign (one city, one niche, tight keyword match) can generate 2-6 qualified leads per month at a cost of $800-$2,000/month in competitive markets.

The mistakes new advisors make on Google Ads: bidding on broad keywords ("financial advisor"), targeting too wide a geography, and sending traffic to a generic homepage. Keep it tight.


Not every marketing channel is appropriate at every stage of a business. The channels below have legitimate uses for large, established practices — but for a new advisor with under $25M AUM and under $3,000/month in marketing budget, they destroy cash without building pipeline.

National TV and Radio: CPMs are high, conversion tracking is nearly impossible, and the audience is diffuse. The advisors who run television ads profitably have recognizable brands, proven conversion rates from those specific markets, and marketing budgets north of $20,000/month. New advisors are not in that position.

Billboards: Brand awareness channels work when there is already something to be aware of. A billboard that says "Oliwer Jonsson, Financial Advisor, (703) 555-1234" generates zero measurable pipeline for a new advisor. The budget is better deployed on LinkedIn content, which compounds.

Broad SmartAsset/Zoe/WiserAdvisor Shared Leads: At $200-$600 per shared lead, you are competing with 3-5 other advisors for the same prospect. New advisors — without brand recognition, without published reviews, without a strong online presence — lose that competition more often than they win it. The math typically requires a 20-30% close rate on these leads to make the CPL work, and most new advisors close 5-15% from cold shared leads.

National PPC with broad match keywords: Bidding on "financial advisor" nationally produces massive click volume at $8-25 per click and conversion rates below 1%. At a $2,000/month budget, that produces fewer than 3 qualified leads in a month. Save the Google Ads budget for hyper-local, niche-specific keywords.


The 12-Month Marketing Roadmap for a New Advisor

The table below is built on what works in practice. It is not a guarantee — your market, niche, and starting network affect the timeline. But the sequence is based on the order in which activities compound most efficiently.

Month Primary Focus Key Activities KPIs to Track
1-2 Foundation Finalize niche + ICP. Build LinkedIn profile to "All-Star" status. Set up CRM (free HubSpot or Redtail). Identify 10 COI targets. Profile views, connection acceptance rate, 10 COI meetings booked
3-4 Organic Momentum 3x LinkedIn posts/week. 10 COI coffees completed. First free seminar or webinar. 5 DM outreach/day. 500+ LinkedIn followers in niche, 2-3 discovery calls/month, 1 referral from COI
5-6 Pipeline Building Launch referral ask program with existing clients/contacts. Begin SEO content (2 articles/month). Install Pixel and build warm audience. 5+ discovery calls/month, 200+ website visitors/month, 3+ referrals in period
7-8 Paid Amplification Launch Meta retargeting ($600-800/mo). Test narrow LinkedIn lead gen ad. Continue COI + referral system. 8-12 conversations/month, CPL < $200 from retargeting, close rate tracked
9-10 Optimization Double down on the 1-2 channels producing the best CPL. Cut what is not converting. Begin podcast outreach. 10-15 conversations/month, 2-3 new clients/month, $10-15M AUM progress
11-12 Scale Review Evaluate paid channel results. Expand SEO content cadence. Build case studies from first client wins. Consider local Google Ads. 3-5 new clients/month, close rate 25%+, referral system producing 1-2/month passively

By month 12, a new advisor who executes this roadmap should have 8-15 clients, $8-20M AUM (depending on niche), and a clear picture of which 1-2 channels to invest in year 2.

For a guide on getting from zero to first clients, see how to get clients as a financial advisor.


Building Authority Fast: Thought Leadership and Credibility Signals

For a new advisor, the trust deficit is the most significant marketing obstacle. A prospect who has never heard of you needs a reason to believe you can handle their retirement savings better than the advisor they found first.

Authority signals close that trust gap faster than any ad.

Certifications displayed correctly. Your CFP, CFA, ChFC, or CDFA designation is not just a credential — it is a trust shortcut. Display it prominently on your website, your LinkedIn headline, and every piece of content you produce. According to CFP Board research, advisors who display their CFP certification convert prospects at higher rates than non-CFP advisors at equivalent experience levels. The CFP certification page at cfp.net includes resources on how to properly display the marks.

Pillar content. A single long-form guide — "The Complete Guide to FERS Pension for Federal Employees in Virginia" — does more for your authority than 50 short LinkedIn posts. It demonstrates depth, it ranks on Google, and it becomes the asset you share with every COI partner and prospect.

Podcast appearances. Being interviewed positions you as the expert by definition. The host asks you questions; you give authoritative answers. For a prospect who listens to the episode, you are the authority before they ever speak to you.

Published in trade or local media. A quote in a local business journal, a contributed article on a financial planning blog, or an appearance on a local news segment all transfer credibility from the publication to you. This is not as hard to get as most new advisors assume. Local media actively needs sources. Reach out to a financial journalist at your regional business journal with a specific data point or story angle they can use.

Third-party reviews. Under FINRA's 2023 marketing rule (discussed below), testimonials are now permitted with proper disclosures. Getting your first five Google reviews from actual clients creates social proof that a new advisor without reviews cannot counter. Do this as soon as you have clients who are willing.


Compliance Basics Every New Financial Advisor Must Know Before Marketing

Marketing compliance in financial services is not optional, and violations carry real consequences — fines, license suspension, and registration issues. New advisors often make compliance mistakes not out of bad intent but out of not knowing the rules. This section gives you the foundation.

FINRA Marketing Rule (Rule 2210). For broker-dealer affiliated advisors, FINRA Rule 2210 governs all communications with the public. It requires that all marketing communications be fair, balanced, and not misleading. New advisors at broker-dealers must typically have their marketing materials reviewed and approved by a designated Principal before distribution. The full rule is available at finra.org. Do not publish a website, LinkedIn post, or ad without understanding whether your firm requires pre-approval.

The Testimonial Rule (SEC Marketing Rule, effective 2023). The SEC's updated marketing rule — which applies to Registered Investment Advisers (RIAs) — now permits testimonials and endorsements, but with specific requirements: the testimonial cannot be compensated without disclosure, it must reflect the honest opinion of the person giving it, and the advisor must include specific disclosures about the relationship. For advisors operating as IARs under a larger RIA, your RIA's compliance department will have specific policies. Follow them. The SEC's full guidance is at sec.gov.

RIA vs. IAR rules. If you are an Investment Adviser Representative (IAR) operating under a Registered Investment Adviser, your compliance obligations run through the RIA. If you start your own RIA, you are directly responsible for compliance with SEC or state rules depending on your AUM. Advisors with under $100M in AUM are generally regulated at the state level. The SEC's investment adviser page outlines the registration thresholds.

Performance advertising. Showing past returns in advertising requires specific disclosures about time periods, benchmarks, and the fact that past performance does not guarantee future results. Many new advisors skip these disclosures without realizing they are required. When in doubt, do not show specific return figures in external marketing.

For a broader guide on the compliance landscape as it relates to advertising specifically, finra.org's advertising regulation section is the authoritative starting point.


Common Marketing Mistakes New Financial Advisors Make

Chasing every channel at once. A new advisor who is simultaneously trying to run Facebook ads, post on LinkedIn, write blog content, attend three networking events per week, and cold call is doing all of them poorly. Pick two channels and build depth before adding a third.

No niche, no positioning. The second most common mistake. "I help people with their finances" is not a positioning statement. It is the reason a prospect clicks away from your website in 8 seconds.

Weak offers. "Schedule a consultation" is not an offer — it is an ask. "Get a free 30-minute FERS pension review" is an offer with a clear benefit. Your call to action must answer the prospect's implicit question: "What do I get out of giving you 30 minutes of my time?"

No CRM from day one. Every advisor who has been in practice for five years has stories about leads that fell through because they had no system for following up. A CRM — even a free one like HubSpot — is not optional. You need to know where every prospect is in your pipeline, when you last contacted them, and what the next step is.

Ignoring referrals in favor of digital. Referrals are the highest-converting and lowest-cost source of new clients in the advisory industry. New advisors sometimes dismiss referrals as "unscalable" and focus entirely on digital channels that take 6-12 months to produce results. A referral system produces results in week 1.

Inconsistent posting without a strategy. Posting on LinkedIn three times one week and then going dark for three weeks does not build an audience. It builds nothing. Consistency over six months beats intensity over two weeks every time.

Skipping compliance review. One non-compliant testimonial or one unapproved advertisement can create a regulatory issue that costs more to resolve than a year of marketing budget. Build compliance review into your process before publishing anything.

For more on scaling a solo advisory practice specifically, see marketing for solo financial advisors.


Your Next Step: Build a Marketing System That Compounds

Marketing for new financial advisors is not about finding a magic channel or running a clever campaign. It is about building a system — a niche that makes you the obvious choice, a referral process that turns clients into advocates, a digital presence that generates trust before a prospect ever speaks to you, and eventually a paid channel that amplifies what is already working.

The advisors who build $100M+ practices in under a decade are not the ones who found the best lead list. They are the ones who defined their niche in year 1, built their referral loop in year 2, and added paid channels in year 3 — in that order.

If you want to build that system and you want support doing it, OJay Media works with financial advisors and wealth managers to build performance marketing programs built specifically for your niche, your compliance requirements, and your growth targets.

Book a free strategy call and we will walk through your current situation, identify the channels with the highest probability of ROI for your specific practice, and give you a clear plan — no obligation, no pitch, just a useful conversation.


Oliwer Jonsson is the Founder of OJay Media, a performance marketing agency that works exclusively with financial advisors, wealth managers, and RIAs. He has worked with advisory practices from solo RIAs to multi-advisor firms and writes about advisor marketing, lead generation, and digital strategy.

External resources referenced: SEC Investment Adviser Information, FINRA Advertising Regulation, CFP Board, Investopedia Financial Advisor Resources, Kitces.com Research, HubSpot Free CRM

Frequently Asked Questions

How long until marketing works for a new financial advisor?

Expect 3-6 months before seeing consistent results from organic channels like LinkedIn and COI outreach. Paid channels like Meta retargeting and Google Ads begin producing data within 30-60 days, but optimization to a profitable cost per acquisition typically takes 60-90 days. SEO content takes the longest — 6-12 months for meaningful organic traffic. The advisors who quit at month 2 are quitting right before results start appearing. Build a 12-month runway in your expectations and your budget.

Should new advisors do paid ads or organic marketing first?

Start with organic channels — LinkedIn, referrals, COI outreach, and free seminars. These channels cost time, not money, and they prove your offer before you spend ad budget. Once you have 5-10 clients, a conversion process that closes 20%+ of discovery calls, and at least 500 website visitors per month, then add paid retargeting. The order matters because paid ads amplify what is already working. They cannot fix an offer that does not convert or a niche that is not defined.

What is the cheapest way for a new advisor to get clients?

The lowest-cost client acquisition path is referrals from existing clients and COI relationships, combined with LinkedIn organic content. At zero ad spend, an advisor who executes consistently on these three channels — COI coffees, LinkedIn content 3x per week, and an active referral ask program — can generate 3-6 discovery calls per month within 90 days. None of these require money. They require showing up consistently for 90 days without seeing much in return, which is why most advisors do not do them.

Do financial advisors need a website to get clients?

You need a website, but it does not need to be expensive. A functional, niche-specific website with a clear headline ("I help federal employees in Northern Virginia plan their retirement"), a strong offer, social proof, and a booking link will outperform a beautiful $10,000 generic site every time. Build on a template platform (Squarespace, Wix, or WordPress), keep it to 4-5 pages, make sure it loads in under 3 seconds on mobile, and make the booking link easy to find on every page. The website's job is to convert traffic that is already warm — not to generate cold traffic by itself.

How many clients does a new advisor need to be profitable?

The break-even point depends on your fee model and overhead. For a fee-only advisor charging 1% AUM with $15M under management — roughly 30-50 clients with average accounts of $300K-$500K — most practices are self-sustaining. For advisors with a hybrid fee model including planning fees or commissions, profitability can come earlier. The first 12 months should target 8-15 clients as a foundation, with a focus on AUM quality (clients who will grow their accounts and refer others) over quantity.

What is the best social media platform for new financial advisors?

LinkedIn is the primary platform for most financial advisor niches because it connects you directly to your professional network, your COI targets, and — depending on your niche — your ideal clients. Facebook remains useful for reaching older demographics (55+) and for running retargeting ads. Instagram works for advisors who serve younger, visual-heavy niches like HENRYs or entrepreneurs. YouTube and podcasting are high-trust but high-production formats that work better in year 2-3 when you have a working pipeline and time to invest in long-form content.

Should new financial advisors cold email to get clients?

Cold email can work for new advisors targeting business owners and professionals who are reachable by email, but it must be done correctly to avoid compliance issues and spam filters. A cold email to a business owner prospect introducing a specific idea or resource — not pitching services outright — can open a conversation. The key is personalization, a clear reason for reaching out, and a low-friction ask (a 15-minute call, not a full meeting). For a structured approach, see cold email for financial advisors.


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Oliwer Jonsson, Founder of OJay Media
About the Author

Oliwer Jonsson is the Founder of OJay Media, a performance marketing agency specializing in financial services. He helps advisors, wealth managers, and insurance professionals generate qualified leads through data-driven content and paid media.

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OJay Media Marketing specializes in performance marketing for registered investment advisers, wealth managers, and insurance professionals. This article is for informational purposes. All paid advertising programs for RIAs and broker-dealers should be reviewed by a compliance professional under the SEC Marketing Rule and FINRA Rule 2210 before implementation.