Navigate ASIC regulations while building genuine client testimonials for your wealth management practice
Financial advisors in Australia must comply with ASIC's advertising standards when requesting and displaying client reviews. This means obtaining genuine testimonials, avoiding misleading claims about investment performance, and maintaining transparent processes. Non-compliance can result in significant penalties and reputational damage to your wealth management business.
According to a 2023 ASIC report, 73% of Australians research advisor credentials and client feedback before engaging wealth management services. For financial advisors, this creates both opportunity and obligation: genuine reviews build trust and differentiate your practice, while ASIC regulations require strict compliance in how you request, display, and manage those reviews.
Breaching these rules can damage your Australian Financial Services Licence (AFSL) and your reputation irreparably.
ASIC's regulatory guide RG 107 sets out the rules for financial services advertising, including testimonials and endorsements.
You cannot use fabricated reviews or incentivise clients to leave positive feedback. Each testimonial should be:
• Obtained from a named, identifiable client • Verifiable upon request by regulators • Representative of typical client experiences • Documented with written consent
Your reviews cannot imply that past performance will continue, that your advice guarantees specific returns, or that you outperform the market consistently. A testimonial saying "I made 15% returns with your advice" without context about market conditions or timeframe is a common violation.
If you display reviews, you cannot selectively show only five-star testimonials while hiding neutral feedback. ASIC expects a balanced picture of client experiences.
If a testimonial comes from a related party—a family member or business associate—this must be clearly disclosed.
Real-World Example: In 2021, ASIC took action against a Sydney-based financial advisory firm that displayed testimonials claiming "guaranteed returns of 8-10% annually" without written consent and without maintaining verification records. The penalty was a $45,000 fine plus mandatory remediation of their website and marketing materials.
Document your process before requesting a single review. Your policy should include:
• Timing: When you'll request reviews (e.g., after annual portfolio reviews) • Method: How you'll request them (email, in-person, online form) • Consent: How you'll obtain written permission • Storage: Where you'll keep verification records • Approval: Who internally approves reviews before publication
Your review request should set expectations upfront, obtain explicit consent, and prevent misleading claims:
Sample Template:
"Dear [Client Name],
We'd love to hear about your experience working with our team. Your honest feedback helps other clients make informed decisions.
If you're willing to share your thoughts, please note: • We'll only use genuine feedback from real clients • You can request your review be removed at any time • We may not use reviews that make specific performance claims • Your feedback will be verified before publication
Please share your experience in 2-3 sentences: [Text field]
May we display your review on our website? ☐ Yes, with my full name ☐ Yes, with first name and initials only ☐ No, keep it private
I confirm this feedback is genuine and based on my actual experience. ☐ Yes"
Before publishing any review:
Create a monthly or quarterly process: collect requests, verify compliance, obtain internal approval, and publish approved reviews.
Your own website is the most compliant channel because you control context, maintain full records, and can update or remove reviews immediately.
Google reviews are valuable for credibility. To manage compliance:
• Don't incentivise reviews • Respond professionally to all reviews, including critical ones • Never delete negative reviews • Monitor for fake reviews
Before using platforms like Finder or Canstar:
• Read their terms regarding advisor participation • Understand their verification process • Ensure they comply with ASIC standards
• Incentivising reviews with gift cards or discounts • Using fake review generation services • Displaying reviews without verification • Creating fake client profiles
Mistake #1: Performance Claims in Client Quotes
Problem: "I've consistently earned 12% annual returns since joining their practice."
Compliant Alternative: "I feel confident my portfolio is structured for my long-term goals, and the team explains everything clearly."
Mistake #2: Soliciting Reviews from Related Parties
Problem: Your business partner's spouse leaves a glowing review without disclosure.
Compliant Alternative: Clearly state the relationship or don't display it publicly.
Mistake #3: Selective Display of Positive Reviews
Problem: You display 47 five-star reviews but hide the three neutral ones.
Compliant Alternative: Display a mix of reviews or use an average star rating.
Mistake #4: No Written Consent Documentation
Problem: A client verbally agrees to a review, but you never get it in writing.
Compliant Alternative: Always use a written consent form (email confirmation counts).
Mistake #5: Not Updating Review Timestamps
Problem: A five-year-old review sits on your website with no date.
Compliant Alternative: Always date reviews and refresh your testimonials page annually.
Phase 1: Foundation (Months 1-3)
• Audit current reviews for compliance • Develop written review request policy • Train your team on ASIC rules • Create compliant request templates
Phase 2: Collection (Months 4-12)
• Request reviews from satisfied clients systematically • Aim for 10-15 new reviews per quarter • Maintain 80%+ approval rate • Document everything
Phase 3: Maintenance (Ongoing)
• Review and refresh testimonials quarterly • Monitor all platforms professionally • Update your policy based on new ASIC guidance • Conduct annual compliance audits
ASIC takes advertising compliance seriously. Recent enforcement actions have included:
• Fines: $20,000 to $100,000+ for serious breaches • Licence conditions: Restrictions on how you can advertise • Remediation orders: Requirements to remove non-compliant content • Reputational damage: Public enforcement action notices
Beyond regulatory penalties, non-compliant reviews damage client relationships and erode trust in your practice.
Before publishing any client review:
☐ Do I have written consent from the client? ☐ Have I verified the client's identity? ☐ Does the review contain any performance claims or guarantees? ☐ Does it imply past performance will continue? ☐ Have I disclosed any material relationships? ☐ Is the review dated and current (less than 3 years old)? ☐ Have I documented approval from my compliance officer? ☐ Have I stored the original consent form?
If you answer "no" to any of these, don't publish the review.
Financial advisor reviews are powerful marketing tools—but only when they're compliant. ASIC's rules exist to protect clients and maintain market integrity. By following these best practices, you build genuine trust, reduce compliance risk, and strengthen your reputation based on real client satisfaction.
The advisors winning new clients aren't those with the most reviews—they're the ones with the most credible reviews. Compliance isn't a burden; it's a competitive advantage.
Can I incentivise clients to leave reviews?
No. ASIC prohibits offering discounts, gift cards, or prize entries in exchange for reviews.
How often should I request reviews?
Aim for 10-15 new reviews per quarter, spread across your client base.
What if a client leaves a negative review on Google?
Respond professionally and factually. Use it as an opportunity to demonstrate your commitment to service improvement.
Can I use reviews from clients who are no longer with my practice?
Yes, but clearly date them and consider archiving reviews older than 3 years.
Do I need compliance officer approval for every review?
At minimum, have a senior team member review all testimonials before publication.
ASIC requires financial advisor reviews to be genuine, verifiable, and from real clients. You cannot fabricate testimonials or incentivise positive feedback. Reviews must be accurate, not misleading about investment performance, and transparently sourced. Non-compliance risks your AFSL and reputation.
Yes, you can request client reviews, but ASIC prohibits incentivising positive feedback or fabricating testimonials. Reviews must come from genuine clients who've used your services. Ensure your request process is transparent and compliant with RG 107 advertising standards.
Breaching ASIC's testimonial and endorsement rules can result in significant penalties, reputational damage, and jeopardy to your Australian Financial Services Licence (AFSL). ASIC actively monitors compliance and can issue enforcement actions against non-compliant advisors.
According to ASIC's 2023 report, 73% of Australians research advisor credentials and client feedback before engaging wealth management services. Genuine reviews significantly influence decision-making, making compliance and transparent review practices essential for competitive advantage.
Compliant testimonials must be from named, identifiable clients who genuinely used your services. They should avoid misleading claims about investment performance, be verifiable, and obtained without incentives. Document your testimonial sourcing process transparently for regulatory compliance.
Genuine reviews build trust, differentiate your practice in competitive markets, and influence client decisions. ASIC data shows 73% of Australians check advisor feedback before engaging services. Compliant reviews demonstrate credibility and transparency to prospective clients.
No, ASIC prohibits testimonials making misleading claims about investment performance. Reviews must be factual and verifiable. You cannot use past performance claims or guarantees in client testimonials, as this violates advertising standards and RG 107 guidance.
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