An accredited investor is an individual with a net worth, or joint net worth with their spouse that exceeds
$1 million at the time of the purchase; or an individual with income exceeding $200,000 in the last two years or
joint income with a spouse exceeding $300,000 for those years and a reasonable expectation of the same in the
current year; or a trust with assets in excess of $5 million, not formed to acquire the securities offered,
whose purchases a sophisticated person makes.
FINRA Rule 2210(d)(6)(B)
Any advertisement or sales literature that includes a testimonial concerning the investment advice or investment
performance of a firm or its products to prominently disclose the fact that: (i) the testimonial may not be representative
of the experience of other customers; (ii) the testimonial is no guarantee of future performance or success; and (iii) if
more than a nominal sum is paid, it is a paid testimonial. FINRA Rule 2210(d)(6)(B) carries forward these disclosure
requirements for retail communications and correspondence, and requires disclosure regarding payment if more than $100
in value (rather than a “nominal sum”) is paid for the testimonial.