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Rebuilding + Exec Coaching Compliance Brief

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← Bob Manthy Hub
Compiled July 13, 2026

Rebuilding + Exec Coaching: Marketing Compliance Brief

Reference for Bob Manthy, LPC. Covers Rebuilding Seminars and Bob Exec Coaching. This is general guidance, not legal advice: it's a research brief built from primary statutory and regulatory sources plus the ACA Code of Ethics, the ethics code that governs Bob's LPC license. Any claim flagged UNVERIFIED means the researcher could not confirm it from a primary source; check it with your board or an attorney before relying on it.

Why this version is different from a generic therapist brief: as an LPC, your governing ethics code is ACA, the strictest of the four Colorado-recognized codes on testimonials (it bars soliciting from both current AND former clients). That makes two questions unusually live for you: whether your ~288 Google reviews for Rebuilding raise a testimonial-solicitation issue, and whether Bob Exec Coaching is cleanly separated from clinical practice. Both are covered in depth below.
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How Colorado's System Actually Works (Read This First)

Colorado consolidated psychologists, licensed clinical/master social workers, LMFTs, LPCs, addiction counselors, and unlicensed psychotherapists into one statute: the Mental Health Practice Act, Title 12, Article 245, C.R.S. Your board (the State Board of Licensed Professional Counselor Examiners) enforces its own practice-act part, but the general "unprofessional conduct" and disclosure rules that govern advertising apply the same way across all four professions through Part 2 (§§ 12-245-201 to 12-245-234).

The statute itself doesn't spell out every advertising rule. Instead it references "generally accepted standards of the professional discipline" (§ 12-245-224(1)(g)(I), quoted below), and for you that discipline-specific standard is the ACA Code of Ethics. Practically: the Colorado statutory layer is the same for everyone, but the ACA testimonial rule is the strictest of the four national codes, so treating ACA as your baseline keeps you safely compliant.

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Testimonials: Your ACA Standard, and the Rebuilding Reviews Question

The rule that governs you: ACA Code of Ethics 2014, Standard C.3.b

"Counselors who use testimonials do not solicit them from current clients, former clients, or any other persons who may be vulnerable to undue influence. Counselors discuss with clients the implications of and obtain permission for the use of any testimonial."

Source: 2014 ACA Code of Ethics, Section C.3.b, "Testimonials." This is the strictest of the four codes Colorado boards reference: it bars soliciting testimonials from BOTH current and former clients, and even when a testimonial is used unsolicited, you're required to discuss implications with the person and get their permission.

The bottom line for you: never solicit a testimonial or review from anyone who is or has ever been a one-on-one therapy client of yours. That's unambiguous under ACA. Unsolicited reviews that arrive organically are a separate, murkier issue, covered next, because it raises a genuine classification question for your specific business model.

The Rebuilding reviews question: this is the highest-value part of this brief for you

Here's the tension. Rebuilding Seminars already has roughly 288 Google reviews and the marketing actively uses review language (the review-mining research at annettethompson.com/hub/rebuilding-review-language is built on exactly this data). ACA C.3.b is written around a therapy relationship: "clients" in a one-on-one clinical sense. Rebuilding is a structured 10-week group seminar, closer to a psychoeducational program than individual psychotherapy. So a real, good-faith question follows: are Rebuilding participants "clients" in the sense the ACA testimonial rule covers, or are they program participants in a group educational format that sits outside that specific rule's intent?

This brief does not answer that question for you, on purpose. It's a genuine gray area that turns on facts a research brief can't settle: how Rebuilding is classified with your board (psychoeducational group vs. group psychotherapy), whether you or co-facilitators are functioning in a clinical role during sessions, and how your malpractice carrier and the LPC board would characterize the relationship. Reasonable, informed people could land in different places on this.

Why it matters practically: if a regulator or opposing party ever characterized Rebuilding participants as "clients" under C.3.b, soliciting reviews from them (even indirectly, like an automated post-seminar "please leave us a review" email) would be the exact fact pattern the rule prohibits. The 288-review base itself isn't necessarily a problem: what matters is whether any of it was solicited, and from whom.

The conservative, safe approach until you get a direct answer from your board or your own attorney:

  • Do not build or run any solicitation (email, text, in-person ask, QR code handed out at graduation) asking a current or former Rebuilding participant to leave a review, no matter how the program is classified.
  • Treat unsolicited, organic reviews (someone leaves one on their own initiative, unprompted) as a separate and comparatively lower-risk category, but still be thoughtful: don't amplify or feature a review that discloses identifiable personal detail about someone's divorce, grief, or mental health situation without their separate permission (see the confidentiality section below, this is a HIPAA/confidentiality issue independent of the testimonial-solicitation issue).
  • Confirm directly with the Colorado LPC board or your own attorney how Rebuilding is classified (psychoeducational group vs. clinical group therapy) and whether that classification changes how C.3.b applies to seminar participants specifically. Get this in writing if you can; it's the single highest-value compliance question in this whole brief given how central reviews already are to your marketing.
  • Until you have that answer, apply the conservative rule above rather than the more permissive read. It costs you very little (you're not running solicitation campaigns today anyway, per this brief's understanding) and it protects you if the stricter classification turns out to be correct.

Per license type, for context (Colorado recognizes four; only LPC applies to you)

LicenseCode / SectionCurrent clientsFormer clients
LPC (you)ACA 2014, C.3.bProhibitedProhibited (explicit)
LCSWNASW, 4.07(b)Prohibited (explicit)Not explicitly named, but broader vulnerability clause may apply
LMFTAAMFTProhibited (per secondary sources, 2026 code)Unclear, UNVERIFIED
PsychologistAPA, 5.05Prohibited (explicit)Not explicitly named

Since ACA is already the strictest standard on this table, being ACA-compliant means you're automatically compliant (or over-compliant) relative to every other license type too.

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Advertising Claims: What's Prohibited and Under What Statute

Colorado's Mental Health Practice Act, § 12-245-224(1), C.R.S., defines "unprofessional conduct" (grounds for board discipline) for every license type under Article 245, including LPCs. The advertising-relevant subsections, quoted exactly from the statute:

(1)(c) "Has used advertising that is misleading, deceptive, or false;"
(1)(j) "Has exercised undue influence on the client, including the promotion of the sale of services, goods, property, or drugs in such a manner as to exploit the client for the financial gain of the practitioner or a third party;"
(1)(g)(I) "Has acted or failed to act in a manner that does not meet the generally accepted standards of the professional discipline under which the person practices. Generally accepted standards may include, at the board's discretion, the standards of practice generally recognized by state and national associations of practitioners in the field of the person's professional discipline."

That last clause, (1)(g)(I), is the legal hook that lets the board treat a violation of the ACA code (guarantees of outcomes, misrepresented credentials, exploitative solicitation) as Colorado "unprofessional conduct." Also worth noting: (1)(q) explicitly permits paying "an independent advertising or marketing agent compensation for advertising or marketing services rendered on the person's behalf by the agent, including compensation that is paid for the results of performance of the services on a per-patient basis." That's a green light for performance-based marketing arrangements, as long as the compensation is genuinely for marketing work and not a disguised referral kickback.

Source: C.R.S. § 12-245-224, Colorado Revised Statutes (2025).

Bottom line on guarantees: don't let Rebuilding or Bob Exec Coaching marketing promise outcomes ("guaranteed to heal your divorce grief," "guaranteed promotion within a year"). That's squarely "misleading, deceptive, or false" under § 12-245-224(1)(c), and the ACA code independently prohibits guaranteeing results.

Confidence: high on the statutory text (verified verbatim). Medium on real-world enforcement aggressiveness; no published board disciplinary decisions specifically about LPC marketing/advertising violations in Colorado were found in this research pass.

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Confidentiality in Marketing: Case Studies, Client Stories, Photos, Before/After

Colorado statute doesn't have a marketing-specific confidentiality clause; confidentiality flows from two places: (1) the general confidentiality obligation in the mandatory disclosure statute (§ 12-245-216(1)(d)(IV): "information provided by the client during therapy sessions is legally confidential"), and (2) HIPAA, which treats anything identifying a client as Protected Health Information (PHI) once tied to their record.

Practical rules that follow, and that apply directly to both Rebuilding and Bob Exec Coaching materials:

  • Testimonials, case studies, "success stories," before/after descriptions, or photos traceable to an identifiable current or former client or participant require a specific, signed HIPAA marketing authorization, not just a general intake consent form. A valid authorization must describe the PHI to be disclosed, the purpose, who will see it, an expiration date/event, and the right to revoke it at any time.
  • Composite or fictionalized stories ("a participant I'll call Sarah...") are the standard safe workaround across the field, provided they're genuinely composite and clearly labeled as illustrative rather than a real person's account.
  • De-identification is harder than it looks in a market like Boulder. A hyper-specific composite ("a 52-year-old Boulder engineer going through a divorce after 20 years") combined with a detailed outcome story can be re-identifiable even with no name or photo. Be cautious with hyper-specific detail in Rebuilding article case studies.
  • This applies just as much to Bob Exec Coaching materials as to Rebuilding, if a coaching story is traceable to a real executive client, it needs the same signed authorization or genuine fictionalization.

Confidence: high on the HIPAA-authorization requirement. Medium on the Colorado-specific statutory confidentiality cross-reference (§ 12-245-220), not independently verified in this pass.

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Credentials: How Your License, Degrees, and Specialties Must Be Represented

Governed by the same § 12-245-224(1)(c)/(g) framework, plus the mandatory disclosure statute's own credential-accuracy requirement.

  • § 12-245-216(1)(b)(II) requires you to give clients, in writing, "a listing of any degrees, credentials, certifications, registrations, and licenses held or completed ... including the education, experience, and training ... required to satisfy in order to complete" each. Whatever's on bobmanthy.com or the Rebuilding site should match what's disclosed and true.
  • "Board certified" / specialist claims: any certification, specialty designation, or credential you advertise needs to be real, current, and from a recognized credentialing body. This applies to any "specializes in divorce recovery" or "trauma-informed" language on either brand's site.
  • License-type accuracy matters especially in Colorado because the state has multiple tiers (licensed, registered, certified, unlicensed). Marketing should never imply a higher tier of regulation than you actually hold; as an LPC, this is straightforward for you, just keep "LPC" accurate and visible wherever credentials are cited.

Confidence: high on the Colorado statute text; medium on generalizing AAMFT-specific credential language (used as an illustrative "generally accepted standards" example in the underlying research) to LPC practice specifically.

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Mandatory Disclosure Statement: What It Requires

Statute: § 12-245-216, C.R.S., "Mandatory disclosure of information to clients." Applies to every LPC.

Required elements, quoted from the statute (as amended; a 2024 amendment via SB 24-115 removed the requirement to explain differing "levels of regulation"):

  • (1)(a) name, business address, business phone number;
  • (1)(b)(II) listing of degrees, credentials, certifications, registrations, licenses, and the education/experience/training required for each;
  • (1)(c) a statement that the practice is regulated by the division (DORA), with the applicable board's address/phone;
  • (1)(d)(I-IV) statements that: the client is entitled to info about methods/techniques/duration/fees; the client may get a second opinion or terminate at any time; sexual intimacy is never appropriate in a professional relationship and should be reported; and session information is legally confidential (with exceptions);
  • (1)(f) a statement about the 7-year record retention limit.

Timing: the client must sign the disclosure form "not later than the second visit" (§ 12-245-216(6)). Failure to comply is independently disciplinable under § 12-245-224(1)(p).

Does this affect the website? Not directly, the statute requires delivery in writing at initial contact and signature by the second visit, not publication on a public site. In practice most Colorado therapists post the disclosure as a downloadable PDF or embed it in intake/e-signature flow. Worth confirming your own disclosure statement is current post-SB24-115 and delivered consistently for both individual clients and, if applicable, Rebuilding intake.

A model template (unofficial): Colorado Association of Psychotherapists, Model Mandatory Disclosure Statement.

Confidence: high on pre-8/7/2024 statutory text (verified verbatim). Medium-high on exact current post-amendment wording (confirmed via secondary summary, not full primary text).

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AI + PHI / HIPAA: Constraints for Your Marketing and Automation

This is general HIPAA knowledge, not Colorado-specific, but it's the biggest risk area for anything automated (email sequences, chatbots, AI-drafted content referencing real people) touching Rebuilding or coaching marketing.

  • The core rule: any tool that "creates, receives, maintains, or transmits" Protected Health Information (PHI) on your behalf is a HIPAA "business associate" and needs a signed Business Associate Agreement (BAA) before touching that data.
  • What counts as PHI here: a client or Rebuilding participant's name plus any health/emotional detail combined; intake answers describing symptoms or circumstances; chat transcripts where someone describes their situation; testimonials/case studies before they're de-identified and authorized.
  • Vanilla consumer AI tools are a real risk: free/consumer ChatGPT (Free, Plus, Team) does not sign a BAA. OpenAI offers a BAA for API customers and ChatGPT Enterprise specifically. "I asked ChatGPT to draft this using a real participant's story" is not compliant unless it's a properly contracted enterprise/API integration.
  • The safe architecture: keep PHI out of the marketing layer entirely. Intake, scheduling, and clinical notes belong in a HIPAA-compliant EHR/practice-management system. Email nurture sequences, SEO content, and general automation should run on non-PHI marketing contact data only (name and email someone voluntarily submitted, no clinical or personal-circumstance detail).

Confidence: high on the general HIPAA/BAA framework and ChatGPT-tier distinction. Zapier's current specific HIPAA/BAA offering is UNVERIFIED, check directly before routing any PHI-adjacent data through it.

7️⃣

The Bob Exec Coaching Gray Area: Keeping It Cleanly Non-Clinical

Confirmed baseline: life/business/executive coaches who serve clients exclusively as coaches, with coach-specific training, are exempt from Colorado's mental health licensing requirements, per the scope-of-article exemption in the Mental Health Practice Act (§ 12-245-217, "Scope of article - exemptions"). The exact statutory text of § 12-245-217 is UNVERIFIED in this research pass (corroborated by strong secondary sources and the DORA "Unlicensed Psychotherapy" program structure, but not independently pulled verbatim); worth confirming primary text before relying on it in writing.

The gray area that matters for you: a licensed LPC who also markets "coaching" is not automatically exempt just by using the word "coach." If the coaching still constitutes "the practice of ... licensed professional counseling [or] psychotherapy" in substance (same population, addressing mental health symptoms, using clinical technique), the board can treat it as practice under your license, meaning all the ACA testimonial/advertising/confidentiality restrictions still apply regardless of the "coaching" label. This is a well-known compliance trap industry-wide, and boards look at substance over label.

Good news specific to your setup: executive/leadership coaching (Bob Exec Coaching's actual scope, goal-setting, leadership performance, career navigation for founders and executives) is more plausibly, genuinely non-clinical than, say, a "divorce coaching" offering would be. Working with executives on leadership silence, achievement identity, or performance blind spots is substantively different work from treating a diagnosed mental health condition. That's a real, defensible separation, not just a label swap. But "more plausible" isn't "automatic," so the same discipline still applies:

  • Different clientele: keep Bob Exec Coaching clients distinct from current or former Rebuilding participants and individual therapy clients where possible. Coaching a former therapy client blurs the line the fastest.
  • Non-clinical scope: frame coaching engagements around goal-setting, accountability, leadership skill-building, not treating a diagnosed condition or using clinical techniques (even informally).
  • Separate branding and intake: bobmanthy.com's exec-coaching positioning and intake flow should read as distinct from a therapy engagement, different framing, different forms, ideally different scheduling/contract paperwork.
  • Once that separation is genuinely in place, the looser coaching marketing standards (testimonials, outcome-oriented claims, more assertive language) become available to the exec-coaching side specifically, without importing risk into your LPC license. Until then, treat exec-coaching marketing under the same ACA-level caution as therapy marketing.

Confidence: medium-high on the coaching exemption's existence and general substance. Low on the exact statutory text of § 12-245-217, verify against primary source before quoting it anywhere official.

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What This Means for Your Marketing, Practically

Safe to run, low compliance risk

  • SEO content and website copy describing services, approach, credentials (accurately), and specialties (accurately), for both Rebuilding and Bob Exec Coaching.
  • Non-PHI lead-generation forms: "book a consult" contact forms collecting name/email/phone/preferred time only, no clinical detail requested.
  • Local SEO, Google Business Profile optimization, directory listings, schema markup: none of this touches ethics-code territory.
  • Educational blog content ("how group support helps after divorce," "what executive coaching actually covers") as long as it avoids outcome guarantees or unsubstantiated superiority claims.
  • Paid advertising for either brand generally, subject to truthful-advertising rules. Avoid outcome-guarantee language.
  • Using the existing review-language research (the 288-review mining project) to inform organic, unsolicited-review-based copy and SEO, since that research draws on reviews already given, not solicited by you going forward.

Avoid, or handle with explicit written protocols

  • Never build an automated "leave us a review" trigger tied to seminar completion or session data, for Rebuilding or individual therapy. This is the single highest-risk automation given the open question above; until the classification question is resolved, treat any solicitation, automated or manual, as covered by C.3.b.
  • Don't draft or imply outcome-guarantee language anywhere ("guaranteed to heal," "you will feel whole again," "guaranteed promotion"), regardless of brand.
  • Don't build case-study or success-story content without a documented HIPAA marketing authorization, or unless it's genuinely composite/fictionalized and labeled as illustrative.
  • Don't connect any AI/automation tool to real participant or client content (transcription, note-summarization, personalized drafting referencing a specific person's situation) without a signed BAA and HIPAA-compliant tooling.
  • Keep Bob Exec Coaching's separation genuine, not just a marketing relabel, before applying looser testimonial or outcome-claim standards to it.
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Sources

Colorado statutes (primary, verified verbatim unless noted)

Colorado regulatory/agency pages

ACA Code of Ethics (primary, verbatim quote obtained), your governing standard

Other national ethics codes (context only, not your governing standard)

HIPAA / PHI / AI compliance (general, not Colorado-specific)

Colorado mandatory-disclosure 2024 amendment coverage (secondary, law-firm summaries)

Related internal research

Compiled July 13, 2026 · Reference for Bob Manthy, LPC · Not legal advice · Private · ← Bob Manthy Hub