Module 1 · investment advisers
Evidence about your public pages, in the words of the supervisor
We load a handful of your public pages, record what is displayed on them, and put each observation next to the wording of the document the supervisor published. You get the page, the date, the screenshot and the reference. What you do with it is your call: this is not legal advice, and we are not your lawyers.
The rules, and what the documents say
Six detectors, six references. Every sentence in quotation marks below is copied from the document named under it; nothing here is our summary of a rule.
D1 — a testimonial or review widget without an adjacent disclosure
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,
2025-12-16.
https://www.sec.gov/files/exams-riskalert-mrkt-rule-2512-508.pdf.
Read on 2026-09-03; recorded in
research/2026-09-briefing-4-sec-ria.md.
D2 — a rating or rating logo without date, period, rater or compensation
Rule reference: 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,
2025-12-16.
https://www.sec.gov/files/exams-riskalert-mrkt-rule-2512-508.pdf.
Read on 2026-09-03; recorded in
research/2026-09-briefing-4-sec-ria.md.
D3 — performance figures or hypothetical/backtested returns on a public page
Rule reference: 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),
2023-09-11.
https://www.sec.gov/newsroom/press-releases/2023-173.
Read on 2026-09-03; recorded in
research/2026-09-briefing-4-sec-ria.md; research/2026-09-sec-document-titles.md.
D4 — a website statement that the firm has no conflicts of interest
Rule reference: 206(4)-1
“refuse[d] all conflicts of interest”
Source: Erste Marketing-Rule-Aktion Meridian Financial, LLC,
2025-09-04.
No document address recorded.
Read on 2026-09-03; recorded in
docs/plan-v2-conformtrail-2026-09-03.md section 2; research/2026-09-briefing-4-sec-ria.md section A1.
D5 — Form CRS on the website
Rule reference: 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,
2021-12-17.
https://www.sec.gov/newsroom/speeches-statements/staff-statement-form-crs-disclosures-121721.
Read on 2026-09-03; recorded in
research/2026-09-form-crs-website-posting.md.
D6 — the page claims FINRA membership and carries no BrokerCheck reference
Rule reference: 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.
Read on 2026-09-03; recorded in
research/2026-09-briefing-4-sec-ria.md.
Dates and wording are given as we recorded them and must be checked against the current official text. This is not legal advice.
Method
What we load
- Your public home page, and the pages linked from it whose address carries one of our keywords: about, team, reviews, testimonials, performance, results, disclosures, disclaimer, crs, relationship summary.
- robots.txt first, at most one request per second, 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: a report names the pages it read.
What is a judgement, not a measurement
Whether a statement on a page is adequate is a judgement for the supervisor. Our detectors report the pattern the supervisor described, with the page, the element and the date. A finding is an observation, not a verdict, and a clean scan is a result about the pages we read on that date, not a statement about your firm.
This is not legal advice.
An example, invented from end to end
Invented example. Example Advisory Partners, LLC does not exist, example-advisory.example is a documentation domain that belongs to nobody, and the numbers below are made up. We publish no page about a named firm and show no screenshot of anyone else’s website. Your own report is reachable only through a private link that we send to you.
Example Advisory Partners, LLC — example report
- Pages read
- 5
- Observations
- 2
- Date
- 2026-09-03
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.
Rule reference: 206(4)-1(b)
Source: SEC Division of Examinations Risk Alert, Additional Observations Regarding Advisers' Compliance with the Advisers Act Marketing Rule, 2025-12-16.
The screenshot of the element sits here.
This example carries none: a picture of a real page would be a picture of a real firm, and that is exactly what we do not publish.
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.
- All six detectors across up to eight public pages
- 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 continues at the monthly price afterwards, or stops.
- Everything in the report
- Three monthly re-scans included
- Continues at the monthly price only if you let it
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. This is not legal advice.