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Series 7: Seeks Business for the Broker-Dealer
Series 7 practice questionhardSocial Media and Digital Communications — Third-Party Posts and Testimonials

A registered representative's LinkedIn profile displays several client testimonials posted by clients without the representative’s solicitation. The representative 'likes' these testimonials and pins them to the top of their profile. Which best describes the firm's compliance obligations?

  1. ANo action required, as testimonials were unsolicited
  2. BThe testimonials become communications of the firm and must comply with FINRA rules, including disclosures if compensation or conflicts exist✓ Correct answer
  3. CTestimonials must be removed, as all testimonials are prohibited
  4. DFirms only need to review the representative's original content, not third-party posts
Explanation

Why BThe testimonials become communications of the firm and must comply with FINRA rules, including disclosures if compensation or conflicts exist

By 'liking' and pinning unsolicited testimonials, the rep has adopted the content, making them subject to FINRA rules regarding testimonials, including requirements for fair disclosure and supervision.

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