Where Does the Link/Button Need to Appear?
The BrokerCheck link is required on pages that meets one of the follow criteria:
- The initial web page that investors will see – the homepage for most websites. This may also apply to any landing pages you create for marketing purposes (i.e. PPC landing page)?
- Any web page that includes a professional profile of a registered advisor who works with retail investors. This does not include a directory list of advisors that is limited to names and contact information.
It is NOT required on third party sites (i.e. social media), email, or text messages.
Setting up the Button/Link
The link should not require significant scrolling down the page to see, and should not be buried in text – set it out separately, or change the font size/color to make it stand out. FINRA specifies that the “footer would not satisfy ‘readily apparent’.”
If you choose to use a hyperlink, FINRA suggests (but does not require) the following text:
- Check the background of this firm on FINRA’s BrokerCheck.
- Check the background of the investment professional on FINRA’s BrokerCheck
They also offer code for pre-made buttons on their resource page.
The hyperlink or link from the button can be set to the BrokerCheck homepage, or to an individual’s or firm’s BrokerCheck page. I would recommend creating the deeper link to your actual page as that is where the user actually wants to go.
The purpose of this article is to summarize Regulatory Notice 15-50 and address the resulting marketing implications. It is not intended to be compliance advice. If you have questions regarding Notice 15-50, please consult your compliance officer.
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