RIA Website Compliance
What firm reviewers check on an RIA or advisor website.
A plain-language 2026 guide for RIAs, breakaway advisors, and hybrid reps. What the SEC Marketing Rule and FINRA Rule 2210 shape on a website, which disclosures need a home, and how to run the build so firm review is fast instead of painful.
Trevor spent a decade in enterprise sales and capital raising across fintech, private wealth, and family offices. This guide describes what a design partner builds around. It is not legal or compliance advice, and your CCO or counsel makes every final call.
Who Reviews What
Your registration decides which rules the website answers to.
The first compliance question about any advisor website is not about design. It is about who regulates the firm, because that decides the review path before launch.
SEC-registered RIA
The SEC Marketing Rule has governed adviser advertising since November 2022. It permits testimonials, endorsements, and third-party ratings with specific disclosures, and it sets strict conditions on any performance content. The CCO reviews the site against the firm's marketing policies.
State-registered RIA
State-registered firms follow their own state's advertising rules, not the SEC Marketing Rule. Some states have adopted similar provisions and some still restrict testimonials more tightly. Confirm the current position of your state administrator before publishing testimonials or ratings.
Broker-dealer and hybrid reps
Advisor sites operating under a broker-dealer may fall within the firm's retail-communication review, supervision, recordkeeping, and filing process under FINRA Rule 2210. The broker-dealer review desk determines the applicable process and final approval.
Insurance-licensed advisors
Annuity and insurance content is regulated by state insurance departments, and carrier marketing rules often apply on top. If the practice mixes advisory and insurance work, the site should keep the 2 offers clearly separated so each can be reviewed under the right standard.
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The Marketing Rule, Applied
6 website decisions the SEC Marketing Rule shapes.
The rule is long, but its effect on a website comes down to a handful of concrete decisions. Here is each one in plain language, with the detail your CCO will care about.
What counts as advertising
The rule generally treats a public website as advertising, including service pages, advisor bios, and posts that promote the firm. Plan every page as if a regulator will read it, because the standard applies to all of it.
The baseline standard
No untrue or misleading statements, and every material claim of fact must be substantiated on demand. Benefits must be balanced with the related risks and limitations. Cherry-picked results and unbalanced claims are the classic failures.
Testimonials and endorsements
Permitted with clear and prominent disclosure of client status, compensation, and material conflicts. Compensated promoters generally need a written agreement, and the adviser must oversee the arrangement. Reviews cannot be cherry-picked in a misleading way.
Third-party ratings
Badges like Best Advisor lists are third-party ratings. The site must disclose the rating date, the period it covers, who produced it, and whether the firm paid in connection with it. Undated award badges with no context are a common deficiency.
Performance content
Gross performance must be accompanied by net performance with at least equal prominence over the same periods, and standard presentations generally use 1, 5, and 10 year periods as of the most recent calendar year end. Many firms keep performance off the marketing site entirely.
Hypothetical and target figures
Backtests, models, and target or projected returns are hypothetical performance. The conditions attached to them make a general public webpage a poor fit, so treat any such figure as specialist territory that the CCO must clear first.
Required Furniture
The pages and links compliance expects to find.
Beyond the claims standards, an advisor website has a short list of fixtures that reviewers look for immediately. Building them in from the start is cheap. Retrofitting them later is not.
Form CRS, posted prominently
An SEC-registered adviser that serves retail investors and has a public website must post its current Form CRS prominently on it. A clearly labeled link in primary navigation or an obvious disclosures page is the working pattern.
ADV brochures and privacy notice
Most firms post the firm-supplied ADV Part 2 brochure and the privacy notice with Form CRS on one disclosures page. Delivery obligations still run through the firm's normal process. The website copy simply makes the documents easy to find.
A visible BrokerCheck link
For broker-dealer and hybrid sites, FINRA Rule 2210(d)(8) requires a readily apparent reference and hyperlink to BrokerCheck on the initial retail page and on any page with a registered person's profile. FINRA guidance says a footer-only link generally is not enough.
Registration language that matches reality
Firm names, marketing names, and registration status must match the firm's filings. A marketing name may require Form ADV disclosure, entity or assumed-name filings, other state requirements, and firm or broker-dealer approval. Confirm the requirements with counsel before publishing it. Fee language matters too: fee-only and fee-based describe different firms, and the wrong term can mislead.
Archiving and books and records
Advisers must keep copies of their advertisements, and the website is one. Firms typically capture versions with an archiving tool or keep dated snapshots and a change log. The build should hand compliance a complete record, not a moving target.
Disclosure placement that survives review
As a conservative design practice, place qualifying disclosures near the claim, in readable type, and without making the reader hunt. The firm's reviewer determines the exact language, prominence, and placement required for the specific communication.
Breakaways and New RIAs
Launching the website while the firm itself is launching.
Breakaway advisors and new RIAs often build while registration, employment, and review questions are still moving. Counsel and the firm's reviewers should define what may be prepared privately, who may see it, and when publication is allowed. The planning framework is in the breakaway advisor website guide.
Use private staging when approved
A private staging URL can support drafting and review when counsel and the firm permit it. The approved audience, access controls, and publication gates should be set before the draft is shared.
Coordinate the exit timing
If you are leaving a broker-dealer or another firm, your agreements, firm policies, registration status, and solicitation rules shape what you can say and when. Counsel should set the publication and announcement sequence for the specific transition.
Get the identity right once
Firm legal name, marketing name, registration status, custodian relationships, and credential marks should be confirmed in writing before they render anywhere. A lapsed designation on a live website is exactly the kind of detail a review desk catches.
Start the compliance file on day 1
Save the approved launch version, start the change log, and turn on archiving the day the site goes live. The first exam request for advertising records is much easier when the record starts at launch.
TMN Fit
A build process shaped for firm review, run by people who know the buyer.
TMN Creative builds advisor and RIA websites with copy drafted for the firm's review, disclosure placement planned from the first layout, staged drafts on a private URL, and a change log the CCO can file. Trevor's decade across fintech, private wealth, and family-office capital raising means the positioning conversation starts at fluency, not from a template.
Interpretation and approval always remain with the firm's CCO, counsel, or broker-dealer review desk. For a named example of this process, read the Hilpan Moxie Wealth Management case study: the firm's compliance consultant reviewed the preview, supplied 3 disclosures that went in verbatim, and confirmed the language on each hypothetical illustration before launch. Confidential private wealth work is described at category level without naming the client. What a professional-firm build includes, phase by phase, and where it stops is on the Custom Studio Build page.
FAQ
Compliance questions advisors ask before a build.
Short factual answers. Your CCO or counsel interprets the rules for your firm and approves the final site.
Can financial advisors use testimonials on their websites?
SEC-registered advisers may use testimonials and endorsements under the Marketing Rule when its disclosure, oversight, written-agreement, and disqualification conditions are satisfied. State-registered advisers follow the rules that apply in their state. Broker-dealer representatives follow their firm's review, supervision, recordkeeping, and filing process under FINRA rules. The responsible firm reviewer makes the final call before publication.
Does an RIA have to post Form CRS on its website?
An SEC-registered adviser that serves retail investors and has a public website must post its current Form CRS prominently on that website. Most firms put Form CRS, the ADV Part 2 brochure, and the privacy notice together on one clearly linked disclosures page. Form CRS is an SEC requirement, so state-registered advisers should confirm their own state's disclosure expectations instead.
Where does the BrokerCheck link go on an advisor website?
FINRA Rule 2210(d)(8) requires a readily apparent reference and hyperlink to BrokerCheck on the initial page a member firm intends retail investors to view and on any page with a professional profile of a registered person who works with retail investors. FINRA guidance says a footer-only link generally does not satisfy the readily apparent standard, so plan for visible placement near the top of the page or beside each advisor profile. This applies to broker-dealer and hybrid advisor sites, and the firm's compliance team confirms placement.
Do advisor websites need to be archived?
SEC recordkeeping rules require advisers to keep copies of their advertisements, and website content generally qualifies, while FINRA member firms have their own retention obligations. Because a website changes over time, firms typically capture versions with a compliance archiving tool or keep dated snapshots and a change log. A well-run build provides staged drafts, a review copy, and a change log so the compliance file stays complete from day 1.
Can a new RIA publish its website before registration is approved?
It depends on the firm's registration path, state law, communications, and facts. Private staging can support drafting and review when counsel and the firm permit it, but those reviewers should define the approved audience, access controls, and publication gates. TMN does not decide when a new firm may hold itself out publicly.
Can an advisor website show investment performance?
Showing performance on a public advisor website is possible but heavily conditioned. Under the SEC Marketing Rule, gross performance must be accompanied by net performance with at least equal prominence over the same periods, standard presentations generally use 1, 5, and 10 year periods as of the most recent calendar year end, and hypothetical performance carries conditions that make it a poor fit for a general public webpage. Many firms choose to keep performance off the marketing site entirely and discuss it in one-on-one conversations instead. The firm's compliance team decides.
Does TMN Creative provide compliance approval?
No. TMN Creative designs and builds the website, drafts clear supportable copy for the firm's review, structures disclosure placement, and delivers staged drafts and change logs that fit a compliance workflow. Interpretation of the rules and final approval always remain with the firm's CCO, counsel, or broker-dealer review desk. TMN does not provide investment, legal, or compliance advice.
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