Module 1: investment advisers
Your public pages, next to the words of the supervisor
We read a handful of your public pages, record what each of them displayed, and put every observation next to the wording of the document the supervisor published. You get the page, the date, the screenshot and the reference. What follows from it is yours and your counsel's to decide: this is not legal advice, and we are not your lawyers.
What we look for
These are the patterns the supervisor described in public. We record whether your pages display them and on which date. Whether a statement on a page is adequate is a judgement for the supervisor, and we do not make it.
- A testimonial or review widget without an adjacent disclosure.
- A rating or rating logo without date, period, rater or compensation.
- Performance figures or hypothetical/backtested returns on a public page.
- A website statement that the firm has no conflicts of interest.
- Form CRS on the website.
- The page claims FINRA membership and carries no BrokerCheck reference.
Source: the public documents in the next section, each with its date and the address at which you can open it, among them the SEC Division of Examinations Risk Alert, Additional Observations Regarding Advisers' Compliance with the Advisers Act Marketing Rule of December 16, 2025: https://www.sec.gov/files/exams-riskalert-mrkt-rule-2512-508.pdf. The patterns above belong to 206(4)-1, 204-5 and FINRA 2210.
Where a pattern needs something we cannot establish for your firm, the report says so instead of guessing. This is not legal advice.
The documents, in their own words
Every sentence in quotation marks below is copied from the document named under it, and every document carries the address at which you can open it yourself. Nothing here is our summary of a rule.
206(4)-1(b)
“testimonials or endorsements that did not provide one or more of the required clear and prominent disclosures”
Source: SEC Division of Examinations Risk Alert, Additional Observations Regarding Advisers' Compliance with the Advisers Act Marketing Rule,
December 16, 2025.
https://www.sec.gov/files/exams-riskalert-mrkt-rule-2512-508.pdf
206(4)-1(c)
“at the bottom of the website pages away from the actual ratings”
Source: SEC Division of Examinations Risk Alert, Additional Observations Regarding Advisers' Compliance with the Advisers Act Marketing Rule,
December 16, 2025.
https://www.sec.gov/files/exams-riskalert-mrkt-rule-2512-508.pdf
206(4)-1(d)
“advertised hypothetical performance to the general public on their websites”
Source: SEC Sweep Into Marketing Rule Violations Results in Charges Against Nine Investment Advisers (2023-173),
September 11, 2023.
https://www.sec.gov/newsroom/press-releases/2023-173
204-5(b)(3)
“Post the current Form CRS prominently on your website, if you have one, in a location and format that is easily accessible for retail investors.”
Source: SEC Staff Statement Regarding Form CRS Disclosures,
December 17, 2021.
https://www.sec.gov/newsroom/speeches-statements/staff-statement-form-crs-disclosures-121721
FINRA 2210(d)(8)
“readily apparent reference and hyperlink to BrokerCheck”
Source: FINRA Rule 2210, Communications with the Public (rulebook page; no issue date established
here).
https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210
Dates and wording are given as we recorded them and must be checked against the current official text. Where a document we hold carries no address we can open, we quote nothing from it and it does not appear on this page. This is not legal advice.
Method
What we read
- Your public home page, and the pages linked from it that cover the areas the rule names.
- robots.txt first, at most one request per second per host, only
GET, and our crawler names itself asConformTrailBot/1.0 (+https://conformtrail.com/bot). - A screenshot of the element an observation is about, so the record shows what a visitor saw on that date.
What we do not check
- Anything behind a login, a paywall or a form. We never sign in and never send a form.
- Your filings, your books, your contracts, your advertising away from the website.
- Whether a disclosure is complete, accurate or sufficient in substance. We record what was displayed and where.
- Pages the crawl did not reach. The report names the pages it read and counts the ones it could not.
What is a judgement, not a measurement
Whether a statement on a page is adequate is a judgement for the supervisor. We report the pattern the supervisor described, with the page, the element and the date. An observation is not a verdict, and a page with nothing on it is a result about that page on that date, not a statement about your firm.
This is not legal advice.
What the report looks like
An invented example, not a customer report with the names taken out. Example Advisory Partners, LLC does not exist, example-advisory.example is a documentation domain that belongs to nobody, and the two observations, the counts and the date below were written for this page. The layout, the sentences and the rule boxes are the ones your own report carries. We publish no page about a named firm and show no screenshot of anyone else’s website, so the report of your firm is reachable only through the private link we send you.
Example Advisory Partners, LLC
- Pages read
- 5
- Pages we could not read
- 1
- Observations
- 2
- Read on
- September 3, 2026
Observation 1 of 2
On https://example-advisory.example/about we observed a client testimonial displayed without an adjacent statement of whether the person is a current client, whether any compensation was paid, and any material conflict of interest.
- Where
- The testimonial block under the heading What our clients say, on https://example-advisory.example/about
- Rule reference
- 206(4)-1(b)
“testimonials or endorsements that did not provide one or more of the required clear and prominent disclosures”
Source: SEC Division of Examinations Risk Alert, Additional Observations Regarding Advisers' Compliance with the Advisers Act Marketing Rule,
December 16, 2025.
https://www.sec.gov/files/exams-riskalert-mrkt-rule-2512-508.pdf
In your report, the screenshot of this element sits here.
It is cropped from the page as it was rendered on the date above, so the record shows what a visitor saw. This example carries none, because a picture of a real page would be a picture of a real firm.
Observation 2 of 2
On https://example-advisory.example/team we observed a statement of FINRA membership displayed without a reference or link to BrokerCheck.
- Where
- The membership line in the footer, on https://example-advisory.example/team
- Rule reference
- FINRA 2210(d)(8)
“readily apparent reference and hyperlink to BrokerCheck”
Source: FINRA Rule 2210, Communications with the Public.
https://www.finra.org/rules-guidance/rulebooks/finra-rules/2210
In your report, the screenshot of this element sits here.
It is cropped from the page as it was rendered on the date above, so the record shows what a visitor saw. This example carries none, because a picture of a real page would be a picture of a real firm.
What else is in the document
- The list of pages we read, and the pages we could not read with the reason.
- A method section: what was looked at, what was not, and what the observations do not say.
- The wording of every document quoted above, with its date and its address.
What it costs
Website Marketing Rule Report
$249 once
Every pattern we observed on your public pages, with screenshot, page, date and the wording of the rule the SEC staff described.
- Every pattern we look for, across the public pages we could read
- Screenshot, URL and date for every observation
- The wording of the rule and the staff document it comes from
- Method section: what we looked at and what we did not
Report plus three months of monitoring
$249 once
The report and the first three monthly re-scans in one payment; monitoring ends when they are over. Nothing renews by itself.
- Everything in the report
- Three monthly re-scans included
- Nothing renews by itself; you order monitoring again or you do not
Marketing Rule Monitoring
$49 per month
Monthly re-scan, an alert when a new pattern appears, and an archive of the page states as they were on each scan date.
- Monthly re-scan of the same pages
- Alert when a new pattern appears
- Archive of page states per scan date
- Cancel any time in the customer portal
Each button opens the order for that offer. Where the card checkout is not open yet, the page it leads to says so and how to order the same offer in writing. No call is needed and none is offered. There is a refund window of 14 days, set out on the refund page. This is not legal advice.