Regardless of whether you’re the chief compliance officer ("CCO") at your registered investment adviser ("RIA") firm or not, you probably know how important it is that you archive every piece of communication intended to be viewed or used by prospects and clients.
If you’re like many advisors, you post blogs and videos to your website multiple times per month, and update the text on different web pages a few times every year. On top of that, websites are incorporating more and more dynamic content, whether it’s video backgrounds or varying content based on a visitor’s specific information. Without a thorough and reliable archiving solution, your RIA firm could end up with gaps in its data history.
1. Meet Books and Records Compliance Requirements
- Rule 204-2 states that all RIA firms must maintain and preserve their required books and records for no less than five years from the end of the fiscal year during which the last entry was made on a relevant record in order to be inspected.
- Those records have to be easily accessible.
- For 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.
If and when your firm is audited, the RIA needs to be prepared to provide the regulatory examination staff with a proper archive of the firm's website history.
2. Protect Your Firm
Unfortunately, complaints from former clients can come down to something as simple as how you phrased one sentence in a blog you wrote five years ago. If you don’t have a record of that sentence, then a complaint or dispute may become your word against theirs.
It won’t be enough to point to what the blog says now. Digital records can easily be edited, revised and deleted. Consider the last time you edited a post on Facebook, or deleted a tweet, or updated a blog on your website.
A website archiving solution will take periodic snapshots of every page of your website or every time it detects a change being made. .
3. Analyze Your Content Over Time
Advisors typically redesign their websites every five or ten years, and every time they do, they tend to lose everything from the previous version. An archiving solution serves as your firm’s own “Wayback Machine,” with greater detail and while simultaneously fulfilling your firm's regulatory compliance obligations.
A website is one of the most effective and efficient communication tools for 21st-century advisors. By leveraging it properly, you can reach a larger audience than ever before—just make sure you’re keeping a proper record of it.