If you are an SEC-registered RIA with a public website, you must post your current Form CRS prominently on it. Beyond that, the site is an advertisement under the Marketing Rule, so every testimonial, endorsement, rating and performance figure on it needs its own conditions and disclosures. Your registration language and fee descriptions must also match your Form ADV. This guide walks through each piece, where it goes and how to keep it current.
TL;DR
- Post Form CRS where retail investors can find it easily. Most firms also link the Form ADV Part 2A brochure from the same place.
- Testimonials and endorsements need clear and prominent disclosures placed next to the claim, not buried in a hyperlink or small print.
- Performance on a website must pair gross with net results and cover the required time periods.
- Website language must match your filings. Update the site whenever Form ADV or Form CRS changes.
- Keep records of what was published and when, so you can show an examiner how each disclosure was handled.
Table of Contents
- What disclosures an RIA website should carry
- Form CRS on your website
- Form ADV Part 2A and how it ties to your site
- Testimonials and endorsements: where disclosures are most often missed
- Performance claims on a website
- The seven general prohibitions as a website checklist
- Social media and content linked from your site
- Keeping website disclosures current
- A pre-launch review you can run in an afternoon
- Our perspective
- Build the site and the system around it
- FAQ
- Sources
What disclosures an RIA website should carry
There is no single "website disclosure rule." The obligations come from several places, and your site has to satisfy all of them at once:
| Item | Where it comes from | What it means for the site |
|---|---|---|
| Form CRS | Rule 204-5 | Post the current version prominently, in a location and format retail investors can easily reach |
| Form ADV Part 2A brochure | Advisers Act brochure rule | Delivered to clients through your normal process; many firms also link it on the site for easy access |
| Advertising content | Marketing Rule | Testimonials, endorsements, ratings and performance carry conditions and disclosures |
| Registration and firm name | Your filings | Names, services and registration status on the site should match what you filed |
| Privacy notice and other firm documents | Your compliance program | Commonly grouped on one disclosures page |
A practical pattern is a single, clearly labeled "Disclosures" link in the main navigation or footer. It holds Form CRS, the Part 2A brochure, your privacy notice and any advertising-specific disclosure language. Reviewers then know exactly where to look, and so do your prospects.
State-registered advisers follow their state's rules rather than the SEC's Form CRS requirement, so confirm with your state securities regulator or compliance consultant which documents apply to you.
Form CRS on your website
An SEC-registered adviser that has a public website must post its current Form CRS prominently, in a location and format that is easily accessible to retail investors. Delivering Form CRS in other ways does not relieve you of your other disclosure duties.
What that looks like in practice:
- A labeled link, not a hunt. Use a plain label such as "Form CRS (Client Relationship Summary)" in the header, footer or a visible disclosures page.
- A format that opens. A PDF that loads on a phone is better than a download that fails.
- Only the current version. When you amend the form, replace the old file and keep the old one in your records.
Form CRS also has an update clock. One practitioner summary of the rule says it must be amended within 30 days when information becomes materially inaccurate, and that changes must reach existing retail clients within 60 days after the amendment is required. Build the website swap into that same workflow so the live page never lags behind the filed version.
Form ADV Part 2A and how it ties to your site
The brochure is a delivery document, but your website often describes the same things in marketing language. Part 2A covers, among other items, your advisory business, fees and compensation, performance-based fees and conflicts, investment strategies and risks, disciplinary information, your code of ethics and personal trading. It must be delivered before or at the time a client signs an advisory agreement, with an updated brochure or summary of material changes delivered each year within 120 days of fiscal year-end.
Three consequences for the website:
- Fee descriptions must not contradict the brochure. If the site says "simple, transparent pricing" while the brochure lists several fee arrangements and conflicts, the marketing copy is the one that creates risk.
- Service descriptions should match. Do not advertise a service on the site that the brochure does not describe.
- Plain English applies. The brochure instructions call for short sentences, concrete everyday words, active voice and tables or bullets for complex material. Your site disclosures read better, and are easier to defend, when they follow the same standard.
The form's instructions also warn that extra information must not be so abundant that required information is obscured. The same instinct applies online: a wall of legal text beneath every page can hide the disclosures that matter.
Testimonials and endorsements: where disclosures are most often missed
The Marketing Rule applies to advisers registered or required to be registered with the SEC that disseminate advertisements. It permits testimonials and endorsements if the adviser meets the disclosure, oversight and disqualification conditions. Ads using them must clearly and prominently disclose whether the person is a client and whether the person is compensated, with further disclosure about compensation and conflicts of interest.
The weak spot is presentation. Summarizing the SEC staff's December 2025 Risk Alert, Katten reports concerns about disclosures that did not say whether a promoter was a client, did not describe compensation or conflicts, or were placed in hyperlinks, smaller or lighter font, or away from the testimonial itself. Another summary of the alert points to small font and text that blends into the page.
A website-ready approach:
- Put the disclosure in the same block as the testimonial, in the same size and contrast as the quote.
- State plainly whether the speaker is a current client, and whether they received cash or other compensation.
- Describe any conflict of interest in a sentence, not a code.
- Do not rely on a footer link that a visitor would have to find on their own.
The same logic of "disclose next to the claim, in words people notice" runs through FTC influencer disclosure guidelines, which is a useful parallel if your endorsements come from people with online audiences. Securities rules still govern the adviser's advertisement itself.
For a deeper look at the testimonial conditions, see our guides on the three conditions for using testimonials and what the SEC rule allows for advisor testimonials.
Third-party ratings
Ratings and awards badges are a common website element. Under the rule, third-party ratings are generally prohibited unless the adviser has a reasonable basis to believe the survey was designed to make favorable and unfavorable responses equally easy and was not built to produce a predetermined result. Per Massachusetts Securities Division guidance, you must also disclose the date and time period of the rating, the identity of the third party and any compensation paid to it. A badge with no date, no rating body and no compensation note does not meet that standard.
Performance claims on a website
If your site shows results, the rule is specific. Under Rule 206(4)-1(d):
- Gross performance must come with net performance of at least equal prominence, in a format that makes comparison easy, over the same period and using the same return type and methodology.
- Results must include one-, five- and ten-year periods with equal prominence, ending no earlier than the most recent calendar year-end. If the portfolio is younger than a period, show the life of the portfolio instead.
You also may not state or imply that the SEC approved or reviewed the calculation or presentation of performance. Avoid any "SEC registered" language that could be read that way.
Short-form social posts deserve care here. Massachusetts regulators note that character-limited platforms can make full and fair disclosure of performance difficult, so many firms keep performance off those channels and point instead to a fully disclosed page.
The seven general prohibitions as a website checklist
Every advertisement, including each page of your site, is subject to the rule's general prohibitions. Per 17 CFR 275.206(4)-1, an ad may not:
- Include an untrue statement of a material fact.
- Omit a material fact needed to keep a statement from being misleading.
- Include a material fact the adviser lacks a reasonable basis to believe it can substantiate on SEC request.
- Discuss potential benefits without fair and balanced treatment of the associated material risks or limitations.
- Reference specific investment advice in a way that is not fair and balanced.
- Include or exclude performance results, or present time periods, unfairly.
- Be otherwise materially misleading.
Read your home page headline, your "About" page and your service pages against that list. Phrases like "proven strategy," "safe retirement income" or "we protect you from market swings" are where items 3 and 4 tend to bite, because each needs substantiation or a balancing statement about risk.
Social media and content linked from your site
Your website often feeds or embeds social content. An adviser is responsible for social posts it writes. It can also be responsible for third-party content that is entangled (the adviser helped pay for or create it) or adopted (the adviser endorsed or approved it after publication). The same guidance notes that deleting unfavorable third-party comments while leaving favorable ones can lead to adoption of what remains. If you embed a review feed or comment widget, decide in advance how it will be moderated and who approves it.
Our compliance content guide covers what blog, video and social content can safely say.
Keeping website disclosures current
Website language goes stale faster than filings do. Set these triggers:
- Annual ADV update. The brochure must be updated each year with the annual updating amendment and promptly whenever information becomes materially inaccurate. Review every service, fee and conflict statement on the site at the same time.
- Form CRS amendment. Swap the posted file and note the date.
- Changes between filings. As a fiduciary you have an ongoing duty to tell clients about material information that could affect the relationship, even when no interim amendment is triggered.
- Policy review. After the December 2025 alert, commentators recommend updating written policies on testimonials, endorsements and ratings, and documenting reasonable-basis determinations, required disclosures, promoter agreements and eligibility checks.
Keep dated copies of every version of the site and each disclosure. Our guide to advertising records to archive for SEC exams lists what to save, and our compliance marketing checklist gives you a pre-publish routine.
A pre-launch review you can run in an afternoon
- Click through every page and list each claim: performance, awards, client stories, "best," "proven," "safe."
- For each claim, write the substantiation or the disclosure that sits beside it.
- Confirm Form CRS and the brochure are linked from one obvious place and are the current versions.
- Compare fee, service and registration statements with your Form ADV.
- Check disclosure size, color and placement on desktop and phone.
- Have your chief compliance officer sign off and archive the approved version with a date.
The broader four-step approach to the Marketing Rule fits neatly around this routine.
Our perspective
Most RIA websites we see fail on presentation, not intent. The disclosure exists somewhere, but it sits in a footer link or in gray text that no prospect would read. Examiners have said they notice that.
We are practicing financial advisors who have grown real advisory practices, so we build marketing the way we would want it built for our own firms. Disclosures are designed into the page from the start, next to the testimonial or claim they qualify, instead of added at the end.
Our approach is a system built around the compliance and long buying cycles that financial services demand, not a generic agency template. That is how a website, a webinar and an email sequence can all say the same compliant thing and keep bringing in qualified prospects.
Josh
Build the site and the system around it
A compliant website is the base of a marketing engine, not the whole of it. Mastermind Advisor builds high-converting advisor websites alongside customized webinars, fully produced seminars, a compliance-friendly content library, automated email follow-up, scheduled social content and CRM integration, all tailored to the regulatory needs and long buying cycles of financial services.
See the full range on our services page, or talk through your goals with us under Growth Strategy.
FAQ
Do all RIAs have to post Form CRS on their website?
An SEC-registered adviser that has a public website must post its current Form CRS prominently, in a location and format easily accessible to retail investors, under Rule 204-5. The requirement is tied to serving retail investors under the rule. State-registered advisers should check their own state's requirements.
Can I put a disclosure in a hyperlink or footer?
The SEC staff has raised concerns about required testimonial and endorsement disclosures placed in hyperlinks, smaller or lighter font, or apart from the testimonial itself. The safer design is to place the disclosure in the same block as the claim, in matching type size and contrast.
Do client testimonials on my site need disclosures?
Yes. The ad must clearly and prominently disclose whether the person is a client and whether they are compensated, along with further compensation and conflict details where they apply. Your chief compliance officer should confirm the oversight and disqualification conditions are met before publishing.
How often should I update website disclosures?
At least annually with your Form ADV update, and promptly whenever something becomes materially inaccurate. Form CRS has its own 30-day amendment window for inaccuracies. Tie site reviews to those filings so nothing drifts.
Sources
- SEC: Investment Adviser Marketing compliance guide
- 17 CFR 275.206(4)-1, Investment adviser marketing
- 17 CFR 275.204-5, Delivery of Form CRS
- Investor.gov: Form ADV Investment Adviser Brochure bulletin
- SEC: Form ADV Part 2 instructions (current)
- SEC: Form ADV Part 2 instructions (Appendix C)
- Massachusetts Securities Division: guidance on IA advertisements
- Katten via JD Supra: Marketing Rule exam findings
- Pulsio: SEC December 2025 Marketing Rule Risk Alert
- TaxShark: How to fill out SEC Form CRS
- Influenna: FTC influencer guidelines