How do you switch email archiving vendors as an RIA?
Export the old archive before the account closes, keep it producible for its full retention period, and run both systems briefly. Turret does not import another vendor's archive.
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Smarsh, Global Relay vs Turret
| Smarsh, Global Relay | Turret | |
|---|---|---|
| Publishes a price | ||
| Advertises a free trial or self-serve start | ||
| Captures mail by journaling as it is sent and received (Global Relay: Exchange Online) | ||
| Captures texts and chat apps |
Their ✗ means the cited pages are silent; Turret’s journaling ✗ means it reads mailboxes instead. Sources
Free tools you can use online
Both are free, and neither needs an email address:
A searchable archive of each mailbox
Turret copies sent and received mail from each connected mailbox and makes it searchable. Shown: the archive search screen.
The details
By Nick Cianci, founder of Turret. He runs Muse Capital Management LLC, an SEC-registered investment adviser.
Last reviewed
The short answer
Plan the switch around the old archive, not the new one. Export it while the account is live, check that it opens, and keep it readable and producible for the rest of its retention period. Turret starts a fresh copy from your mailboxes, so mail permanently deleted from a mailbox can survive only in the old archive.
What this means for your firm
- Find the renewal date and the non-renewal notice window in your agreement and order form today, and calendar the deadline.
- While the contract is live, ask the vendor in writing for a full export: the format, the cost and the time it takes.
- Open the export and search it before you cancel. Keep it, and a duplicate copy, for as long as the records must be kept.
- Write down what you did and when, in the same place your compliance manual says to look.
Connect Turret during its 15-day trial while the old account is live.
Six questions about how your firm keeps and reviews email: take the SEC email-readiness self-check.
Retention years beside the SEC floor
5 years
the rule's minimum
7 years
Turret's policy while you subscribe
- First 2 years in an appropriate office of the adviser
- Rest of the 5 years the rule requires
- Turret retention policy, while you subscribe
The rule counts from the end of the fiscal year in which the last entry was made (17 CFR 275.204-2(e)(1)). Turret's policy counts from the day each message is archived. The bars show policy, not how much a given firm has archived so far.
| Period | Years |
|---|---|
| Rule minimum, 17 CFR 275.204-2(e)(1) | 5 |
| Of which in an appropriate office of the adviser | 2 |
| Turret retention policy, while you subscribe | 7 |
In short
- What a new archive can reach
- What each connected mailbox still holds; mail permanently deleted before connection can survive only in the old archive (Turret)
- What the old archive must still do
- Be indexed, producible on request, and backed by a duplicate copy, generally for five years from the end of the fiscal year of the last entry (17 CFR 275.204-2(e)(1), (g)(2))
- Smarsh and Global Relay
- Both renew automatically by default, in 12-month and two-year terms, and both put export after termination on a fee (Smarsh Services Agreement V.06/26; Global Relay Master terms)
Does Turret import my old vendor's archive?
No. Turret archives from each connected mailbox itself: the last 90 days during the 15-day trial, then back through your retention period, limited to what the mailbox holds. On Microsoft 365 the online archive mailbox is not included. Export the old archive before the account closes.
After the first paid charge, Turret walks each mailbox back through the firm's retention period (your firm's retention policy, 7 years by default). It finds only what the mailbox still contains, and on Microsoft 365 it does not walk the online archive mailbox or Recoverable Items. If a message was permanently deleted from a mailbox, or a departed employee's account was deleted, the old vendor's copy, if it captured one, can be the only copy your firm holds. That is why the export matters more than the new setup.
Turret does capture Trash (Gmail) and Deleted Items (Outlook). Related: Does email archiving capture deleted email?
What Rule 204-2 asks of the old archive
Changing vendors does not end the duty to keep records. Paragraph (e)(1) puts the period on the record, not the vendor:
"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."
17 CFR 275.204-2(e)(1)
The five years generally run from the end of the fiscal year of the last entry (how the clocks work). For electronic copies, paragraph (g)(2) says the adviser must:
"(i) Arrange and index the records in a way that permits easy location, access, and retrieval of any particular record;" … "(iii) Separately store, for the time required for preservation of the original record, a duplicate copy of the record on any medium allowed by this section."
17 CFR 275.204-2(g)(2)
Paragraph (g)(2)(ii) adds prompt production of a complete copy. An export nobody can open or search will not do that, and a single copy leaves (iii) open. Whether an export meets the rule is for your CCO and counsel.
A step-by-step switch plan
- Find the dates. Read the renewal clause and the notice window in the agreement and your order form. Calendar the deadline with a margin.
- Ask for the export in writing, while the contract is live. Ask for the format, the cost, the time it takes, and whether it includes attachments and message dates.
- Run the export and open it. Check that senders, recipients, dates and attachments are there for a few mailboxes, and that you can search it.
- Run both for a short overlap. Connect Turret during its 15-day trial while the old account is live, and check that the same mailboxes and recent mail appear. The overlap has a cost: your old contract probably runs to its renewal date, so you pay both for a while.
- Keep the export and a duplicate copy in separate places, for the remaining retention period.
- Close the old account last, after steps 3 and 5. Record what you did, who did it and when.
Can I export my archive after I cancel Smarsh?
Smarsh's current posted services agreement (V.06/26) says access ends on termination and that, for Professional Archive, export or migration afterwards is professional services at its then-current rates. Your order form may differ; request the export before you cancel.
What the agreement says about the term:
- Renewal: recurring services renew for successive 12-month terms unless the order form says otherwise.
- Notice: Smarsh sends a renewal notice at least 90 days before the term ends; you must give written notice of intent to cancel 60 days before it ends, or you are deemed to have accepted the renewal.
- Early exit: a Minimum Commitment stays due if you end the contract early.
- Deletion: Smarsh deletes Client Data "as soon as practicable."
An earlier agreement version differed on some terms, so read the one your order form incorporates.
As we read it, Smarsh's Data Freedom Guarantee for Professional Archive describes a self-service export at no cost for an active account. The posted agreement puts export after termination under section 6.7.1, as paid professional services. Detail: Turret beside Smarsh.
How much notice does Global Relay need to end a contract?
Global Relay's master terms, as we read them, renew order forms for two-year terms and ask for notice at least 90 days, and not more than 120 days, before the Initial Term ends. Check your own order form for your dates.
The same terms:
- Early exit: the customer has no general right to end the agreement early other than for Global Relay's material breach.
- Access: access to Global Relay Archive ends when the agreement does.
- Export: the customer may engage Global Relay to export a copy of its archived data for a fee set in the order form or at Global Relay's standard rates. A static archive option keeps existing data, with access limited to an administrative user and fees paid in advance.
- Deletion: if the customer neither exports nor preserves the data within 120 days after the services end, the terms treat it as abandoned and let Global Relay delete it.
Global Relay's switching page covers moving into Global Relay, not out. Detail: Turret beside Global Relay.
XYPN Archive and RIA in a Box: closing and exporting
XYPN Archive. XYPN's blog calls it “available only to XYPN members” [7]; its help page lists a non-member option for leavers, by contacting XYPN's archive team [9]. As we read XYPN's help pages:
- To close: your account admin submits a request through the Membership Portal, processed at month end.
- After closing: XYPN says closing does not delete your data and that it retains it for seven years from creation, but not whether a closed account can still reach it; ask.
- Before closing: you can download a date range of up to one year at a time, and emails come as EML.
Detail: Turret beside XYPN Archive.
RIA in a Box (now Comply for RIA). We found only Comply's general terms (March 2026), which do not name RIA in a Box; ask which terms govern your order form. As we read them, they renew for one-year periods with 60 days' notice, make the customer responsible for exporting its data, and let Comply destroy data unless a written request for copies arrives within ten days after termination.
If you relied on Google Vault or Microsoft Purview
Both export, and both expire the files.
- Google Vault: Google says that if you delete a user or a required license, their data "might be irreversibly purged and no longer available to Vault." Vault exports are in PST or mbox, and export files are available for 15 days after you start the export.
- Microsoft Purview: Microsoft's eDiscovery export gives PST files or individual messages, and search export packages expire 14 days after you create them. Microsoft's eDiscovery (preview) page says exporting content needs an eDiscovery user with a Microsoft 365 Enterprise E3 or E5 license.
Export when you are ready to open the files. If you plan to leave the platform's own tools behind, suspend or hold departing accounts first. See Is Google Vault enough for SEC Rule 204-2? and Is Microsoft 365 retention enough for SEC Rule 204-2?.
Where Turret fits
Turret archives sent and received mail from each connected mailbox, Trash included, and reviews outbound mail only, with a short written reason on each flag. Setup is self-serve, with no setup fee and a 15-day free trial. Email is $99 a month with 5 mailboxes included. Spam, drafts and chats are not captured, and Turret does not capture texts or chat apps. If you leave, Turret keeps the archive 60 days after cancellation and exports it on request; a person, not a timer, then deletes it.
Sources
Sources opened October 27, 2026.
- eCFR, 17 CFR 275.204-2, Books and records to be maintained by investment advisers
- Smarsh Services Agreement (current posted PDF, headed V.06/26; smarsh.com/legal-docs/SmarshServicesAgreement-v0626.pdf)
- Smarsh press release, "Smarsh Sets New Industry Standard with Data Freedom Guarantee" (July 31, 2025)
- Smarsh, RIA Compliance Software & Solutions (smarsh.com), Smarsh, Email channel page (smarsh.com), Smarsh, Mobile channel page (smarsh.com)
- Global Relay Master terms of service
- Global Relay solutions for finance, Global Relay Archive (industries and channels), Global Relay for Microsoft 365 Exchange Online connector, Global Relay switching and onboarding
- XYPN blog, "Are You Making Archiving Mistakes in Your Financial Planning Firm?" (updated July 21, 2026)
- XY Archive help center, "Closing Your Account and Deleting Your Data" (last updated March 5, 2024)
- XYPN help center, "XYPN Archive" (page last updated August 18, 2026)
- XY Archive help center, "Accessing Your Raw Data (.eml, .pst)" (last updated March 5, 2024)
- XY Archive help center, "Creating a Download for Social Media and Email" (last updated April 21, 2025)
- Comply SaaS and Professional Services Terms and Conditions (comply.com, last updated March 2026; does not name RIA in a Box)
- Google Vault overview (knowledge.workspace.google.com), Google Vault, "Export data from Vault" (knowledge.workspace.google.com, updated October 22, 2026)
- Microsoft Learn, "Export search results in eDiscovery" (ms.date June 23, 2026)
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