Skip to content

Do RIAs need to archive their website?

Pages on your site that offer your advisory services are generally advertisements, and Rule 204-2 requires a copy of each one you disseminate.

$99/mo for 5 mailboxes · no setup fee · 15-day free trial

Talk to us

Built by an RIA, for RIAs.

Wayback Machine vs Turret

Wayback Machine beside Turret
Wayback Machine Turret
Re-checks a page you name on a schedule; saves each change
Stores a SHA-256 hash with each capture
Saves a page you name on a domain you don't own

✗ for the Wayback Machine means archive.org's pages state no such feature; ✗ for Turret means approval first. Sources

Free tools you can use online

Both are free, and neither needs an email address:

Marketing Rule checklist

SEC email readiness self-check

The details

By Nick Cianci, founder of Turret. He runs Muse Capital Management LLC, an SEC-registered investment adviser.

Last reviewed

The short answer

Generally, yes for the pages that offer your advisory services. Rule 204-2 requires a copy of each advertisement you disseminate, and the SEC has settled cases against advisers for not keeping copies of their website ads, among them a firm whose web vendor did not keep copies of all of them either. The rule names no method; plan to produce every version on request.

Whether a given page is an advertisement is a judgment for your CCO and counsel.

What this means for your firm

  • List the pages on your site that offer your services (home, services, fees, contact, a "work with us" closing on an article) and the pages that are brand or educational content. Write the list down and date it, then save a dated copy of every page on it this week; how long to keep advertisements covers the clock.
  • Find out who holds copies of your pages today. If it is a website builder or host, ask in writing whether it keeps every published version with dates, and how fast you can get them.
  • Capture the site before you redesign or move it. A page you replace is still a page you published.
  • Name the website in your marketing policies. The SEC staff's April 2024 risk alert reported policies that "Did not address applicable marketing channels utilized by the advisers, such as websites and social media." That is a staff observation, not a rule.

Turret's website archive keeps those copies for you; "Where Turret fits" says what it captures.

In short
Which pages
A communication made to more than one person that offers your advisory services is an advertisement; generic brand content, educational material and market commentary generally is not (17 CFR 275.206(4)-1(e)(1); IA-5653, pp. 36-37)
What to keep
A copy of each advertisement the adviser disseminates, directly or indirectly (17 CFR 275.204-2(a)(11)(i)(A))
How long
Not less than five years, the first two in an appropriate office, from the end of the fiscal year the advertisement was last published or otherwise disseminated (17 CFR 275.204-2(e)(3)(i))

Is a firm's website an advertisement?

Pages that offer your advisory services generally are. Rule 206(4)-1(e)(1) covers communications to more than one person that offer your services, and a public website reaches more than one person. Generic brand content, educational material and market commentary generally are not.

The rule's definition begins:

"Any direct or indirect communication an investment adviser makes to more than one person ... that offers the investment adviser's investment advisory services with regard to securities to prospective clients ... or offers new investment advisory services ... to current clients ..."

17 CFR 275.206(4)-1(e)(1)(i)

In the Meridian order, about an advertisement on its website, the SEC wrote: "As the communication was published on a public website, it was made to more than one person." The adopting release says other content that offers or promotes the adviser's services on an adviser's own website would likely meet the definition (p. 23, fn. 50), and that "Generally, generic brand content, educational material, and market commentary would not meet the revised definition of an advertisement" (pp. 36-37).

What does Rule 204-2 require a firm to keep?

You keep a copy of each advertisement:

"A copy of each ... Advertisement (as defined in § 275.206(4)-1(e)(1) of this chapter) that the investment adviser disseminates, directly or indirectly, except: ..."

17 CFR 275.204-2(a)(11)(i)(A)

In plain terms, at least five years after the fiscal year the ad was last published:

"... shall be maintained and preserved in an easily accessible place for a period of not less than five years, the first two years in an appropriate office of the investment adviser, from the end of the fiscal year during which the investment adviser last published or otherwise disseminated, directly or indirectly, the notice, circular, advertisement, newspaper article, investment letter, bulletin or other communication."

17 CFR 275.204-2(e)(3)(i)

The adopting release says the rule "does not prescribe or prohibit any particular method of maintaining records" (p. 245), and accepts e-mail archives, including a vendor's, "provided that the adviser can promptly produce records" (pp. 245-246). It says nothing specific about websites; extending it to one is our reasoning. See how long to keep advertisements.

What did the SEC find in the Meridian order?

On September 4, 2025 the SEC issued a settled order against Meridian Financial, LLC (IA-6916), an adviser reporting about $258 million in regulatory assets and a client base of individuals. Meridian consented without admitting or denying the findings; the order imposed a censure, a $75,000 civil penalty and undertakings. It states:

"Meridian also failed to maintain copies of advertisements that appeared on its website."

IA-6916

The order also says Meridian "retained a third-party service provider to construct and maintain its website, but neither Meridian nor this third-party service provider kept copies of all of the advertisements on the website that were published and available to the public." It adds that Meridian "was unable to provide all of the website advertisements requested by the staff during the Commission's investigation from time periods prior to December 2023."

The order cites Section 204(a) and Rule 204-2(a)(11) for the records failure. An order binds the respondent, not other advisers; it shows how the SEC read a gap in website copies.

Is the Wayback Machine enough?

No, not on its own. archive.org's help pages say "We can't guarantee that your site has been or will be archived." The pages we read also state no crawl schedule for your site, and say nothing about verifying that a capture is unaltered.

That means gaps you can't rule out. In archive.org's own words:

  • "Some sites may not be included because the automated crawlers were unaware of their existence at the time of the crawl."
  • "Save Page Now" can "save a specific page one time"; it "does not currently add the URL to any future crawls nor does it save more than that one page."
  • "Site owners might have also requested that their sites be excluded from the Wayback Machine."
  • "Not every date for every site archived is 100% complete."

Rule 204-2 asks for a copy of each advertisement. A capture archive.org does not promise cannot be your only copy. Use it as a cross-check.

Can a website vendor keep the copies for you?

A vendor can hold the copies, but the orders show they help only if you can get them.

In Macroclimate LLC (IA-6409, September 11, 2023), copies were unavailable because "the earliest versions of the relevant webpages ... were not saved before they were later revised." MRA Advisory Group (IA-6411, same date) could not produce ads "because it had failed to ensure that the advertisements had been archived by an outside service provider." GeaSphere (IA-6585, April 12, 2024) "failed to keep copies of advertisements published on its public website." Each consented without admitting or denying; reported assets, with Meridian's, run from about $86 million to $258 million.

Meridian's compliance manual required a third party keeping records to agree "to provide those records promptly upon request"; the order says it had not obtained that agreement.

If your website builder or host keeps version history, ask whether it holds every published version with dates, whether you can export it promptly, and whether that is promised in writing.

Should you archive your website before a redesign?

Yes. Under our reading of Rule 204-2(a)(11), a page you replace is still an advertisement you disseminated, and its copy is kept for the period. Capture the site before it changes; a page nobody saved cannot be copied afterward.

We found no SEC statement about redesigns, platform migrations or keeping earlier versions of a site. The reasoning rests on two rule texts. Paragraph (a)(11)(i)(A) asks for "a copy of each" advertisement disseminated. Paragraph (e)(3)(i) runs the period from the end of the fiscal year in which it was "last published or otherwise disseminated."

For example, a firm with a calendar fiscal year replaces its fees page on March 15, 2027. The page was last published in fiscal year 2027, so the five years run from December 31, 2027, to at least December 31, 2032. That is our arithmetic from the rule's text, not SEC guidance.

Before a relaunch or platform move, save the old site and confirm the old host will release its copies before you cancel it.

Where Turret fits

Turret checks each public page you track on your site on a regular schedule and saves a dated version when it has changed: the HTML plus a full-page capture where possible, each with a SHA-256 hash, kept for your firm's retention policy. Capture starts the day you add a page; earlier versions are not recovered. Other domains need Turret's approval; social media and review sites are not captured. Included with Email ($99/mo, 5 mailboxes), Marketing ($99/mo, 5 submitters) and Complete. No setup fee, 15-day free trial. See website archiving.

Sources

Try Turret on your own firm's mail.

Your admin grants read-only access once. You add a card at the end of setup; nothing is charged during the 15-day free trial. No setup fee.

Prefer to talk it through first? Talk to us