How do you set up email archiving for a new RIA?

Rule 204-2 names no start day. Put business mail on Google Workspace or Microsoft 365, and connect archiving before the first client email.

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Built by an RIA, for RIAs.

Smarsh, Global Relay vs Turret

What a new firm can find out before talking to anyone, from each vendor's own pages
	Smarsh, Global Relay	Turret
Price published
Says there is no setup fee
Describes self-serve setup
Captures texts and chat apps

✗ means not stated on the pages we checked; for texts and chat, it means Turret does not capture them. Sources

Free tools you can use online

Both are free, and neither needs an email address:

Marketing Rule checklist

SEC email readiness self-check

Archive search, sent and received

Turret's archive search: sent and received mail from each connected mailbox, Trash included, searchable in full text. Connect it before the first client email and the archive holds the firm's mail from the day you connect.

From Turret's demo firm; example data.

The details

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

Last reviewed October 27, 2026

The short answer

Rule 204-2 applies to every adviser "registered or required to be registered", and its text names no start day. Build the mail setup before the first client email: business-domain mailboxes, archiving connected, and written review and departure steps. Mail from a previous firm is a separate matter, covered below.

What this means for your firm, in order

Set up firm-domain mailboxes on Google Workspace or Microsoft 365 for all client business, and keep personal accounts out of it.
Connect archiving before the first client email, so the firm's mail is kept from the start.
Write the review procedure and the retention policy: who reviews, how often, what gets recorded, and how many years you keep.
Write the departure step before anyone leaves.

Turret archives sent and received mail for a firm on Google Workspace or Microsoft 365, flags outbound mail with a written reason for each flag, and has a published price, no setup fee and a 15-day free trial. Details are under "Where Turret fits".

Six questions about how your firm keeps and reviews email: take the SEC email-readiness self-check. It is a check of your own practices.

Setup in five steps

Setting up email archiving, step by step

Choose a product

Email, Marketing or both
Pick your mail platform

Google Workspace or Microsoft 365
Authorize read-only access

Your admin approves it once
Verify the connection

Turret checks it can read one mailbox
Add a card

Archiving begins after this step

In short

Who the rule covers: "Every investment adviser registered or required to be registered under section 203 of the Act" (17 CFR 275.204-2(a), via Cornell LII)
Registration timing: The SEC has 45 days to act on an initial registration request (SEC, Form ADV and IARD FAQ)
State-registered advisers: A state's own recordkeeping rule governs; NASAA's model rule is a model, and one version incorporates Rule 204-2 (NASAA Model Rule 203(a)-2)

When does Rule 204-2 start to apply to a new RIA?

Rule 204-2 applies to an adviser "registered or required to be registered" under section 203. No SEC page we found fixes the exact starting day. Connect archiving before the first client email; that is a practical step, not a rule.

"Every investment adviser registered or required to be registered under section 203 of the Act (15 U.S.C. 80b-3) shall make and keep true, accurate and current the following books and records relating to its investment advisory business"

17 CFR 275.204-2(a)

The SEC has 45 days to act on an initial registration request, or longer if the applicant consents (Advisers Act section 203(c)(2); SEC Form ADV and IARD FAQ). A firm's first emails can predate the effective date, and the rule marks no day before which they do not count. Whether a given period or message is covered is a judgment for your CCO and counsel.

For what the rule asks you to keep, see Which emails must an RIA keep?.

Which rule applies to a state-registered adviser?

A state-registered adviser follows its state's recordkeeping rule. NASAA publishes a model for states to adopt; the model is not itself the law, and a state's own rule governs.

"This rule is intended for jurisdictions that have adopted the Uniform Securities Act of 1956."

NASAA Model Rule 203(a)-2, note on page 1

The model's main version tracks the SEC rule's four subjects and five-year floor. A second version is for states that incorporate the SEC rule:

"(1) Those books and records required to be maintained and preserved in compliance with Rule 204-2 of the Investment Advisers Act of 1940 ..., notwithstanding the fact that the investment adviser is not registered or required to be registered under the Investment Advisers Act of 1940."

NASAA Model Rule 203(a)-2, alternative 2

Read your state's rule text. The retention answer cites Oregon's.

A day-one email checklist for a new RIA

A firm domain on Google Workspace or Microsoft 365. Guides: Google Workspace email archiving, Microsoft 365 email archiving.
No personal accounts for client business. The 2018 SEC staff risk alert covered personal email, social media and apps, not firm email. Among its listed practices for advisers who permit personal email: "adopting and implementing policies and procedures for the monitoring, review, and retention of such electronic communications".
Archiving connected before the first client email. Turret copies each mailbox on a schedule; a message purged before the copy is not captured.
A written review procedure: who reviews, how often, what gets written down. No SEC rule we found sets how often; see How to review RIA email.
A retention policy. Rule 204-2(e)(1) sets a five-year floor from the end of the fiscal year of the last entry; Turret counts your retention period (7 years by default) from the day a message is archived. See retention.
A departure procedure. Suspend (Google) or disable (Microsoft) a departing person's account; do not delete it. See Does email archiving capture deleted email?

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What the SEC has said about newly registered advisers

SEC staff have said they examine new registrants early. The Division of Examinations' March 2023 risk alert:

"the Division has prioritized examining newly-registered advisers within a reasonable period of time after the adviser's SEC registration has become effective."

SEC Division of Examinations, Observations from Examinations of Newly-Registered Advisers (Mar. 27, 2023), p. 2

The fiscal year 2027 priorities repeat the emphasis:

"The Division will continue to prioritize examinations of advisers that have never been examined, with particular emphasis on recently registered advisers."

SEC Division of Examinations, Fiscal Year 2027 Examination Priorities, p. 7

The 2023 alert's list of requested items names compliance policies and procedures, and no email-specific item.

Staff statements are not rules. The priorities document says of itself that it "has no legal force or effect: it does not alter or amend applicable law, and it creates no new or additional obligations for any person". Have the written policies from the checklist ready.

What about email from your previous firm?

No SEC source we found says who owns the email you wrote at your last firm; that turns on your agreement with that firm. Rule 204-2 applies to your own firm's records, so a new firm's archive starts with the mail its own mailboxes send and receive.

A situation the rules address: showing performance earned at a previous firm. The Marketing Rule sets conditions:

"(7) Any predecessor performance unless: (i) The person or persons who were primarily responsible for achieving the prior performance results manage accounts at the advertising adviser; …"

17 CFR 275.206(4)-1(d)(7)

And Rule 204-2 asks the advertiser to hold the support:

"All accounts, books, internal working papers, and any other records or documents that are necessary to form the basis for or demonstrate the calculation of any performance or rate of return …"

17 CFR 275.204-2(a)(16)

Paragraph (a)(16) reaches such material in a communication disseminated "to any person" outside the firm.

Where Turret fits

Setup is a self-serve wizard of about ten minutes, with no setup fee and a 15-day free trial. Turret archives no mail before the card step. Backfill follows message dates: the last 90 days during the trial, then back through your retention period after the first paid charge, limited to what the mailbox holds. After a Google suspension, Turret runs a final full pass. Email is $99/mo for 5 mailboxes. Turret does not import another archive, capture texts or chat apps, or review inbound mail.

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Sources

Sources opened October 27, 2026.

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.

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