RIA Glossary / Firm Roles & Structure

Promoter

Quick Answer
A promoter — the term the Marketing Rule uses in place of the older “solicitor” language — is any person compensated for referring clients to an investment adviser, or who otherwise endorses the adviser in exchange for compensation. Promoters above certain thresholds require a written agreement and specific disclosures.
Reviewed by Sam Carter, Director of Registration Services
Last reviewed September 18, 2026

What Is a Promoter Under the Marketing Rule?

Under the previous cash solicitation rule, “solicitor” specifically referred to someone paid a fee for client referrals. The SEC’s New Marketing Rule broadened this into “promoter,” which also captures compensated endorsers such as influencers or affiliates who tout the firm’s services, not just traditional referral arrangements. Promoters receiving more than a de minimis amount of compensation require a written promoter agreement, and clients must be told about the compensation arrangement and any material conflicts it creates.

Firms working with promoters need oversight procedures to confirm the promoter’s statements are accurate and comply with the same standards applied to the firm’s own advertising.

Why it Matters

As influencer and affiliate marketing has grown in the advisory space, promoter compliance has become a more active area of regulatory attention — informal referral relationships that predate the Marketing Rule may not meet current requirements.

Frequently Asked Questions

Is a solicitor and a promoter the same thing?

Promoter is the current Marketing Rule terminology; it covers what used to be called solicitors plus a broader category of compensated endorsers.

Do I need a written agreement with every referral source?

Only above the rule’s de minimis compensation threshold — but best practice is documenting all paid referral relationships regardless.
Related Terms

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