What SEC and FINRA Actually Require for Your Investment Firm's Website Content

Investment firm websites operate under overlapping regulatory frameworks depending on your registration status. Understanding which rules apply to your firm is the first step toward compliant SEO content.

For Registered Investment Advisers (RIAs): The SEC's Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act) took effect November 2022, replacing the prior advertising and solicitation rules. This rule governs all 'advertisements'—defined broadly to include most website content, blog posts, case studies, and social media posts that offer or promote advisory services.

For Broker-Dealers: FINRA Rule 2210 (Communications with the Public) establishes three categories of communications: institutional, retail, and correspondence. Most website content falls under 'retail communication,' requiring principal approval before use. FINRA Rule 2241 adds requirements for research communications specifically.

For Dual-Registrants: Both frameworks apply. Your compliance program must address SEC requirements for advisory content and FINRA requirements for brokerage content—which can create complexity when a single page discusses both service types.

State securities regulators add another layer. While the Marketing Rule preempts some state advertising rules for SEC-registered advisers, state-registered advisers face their state's specific requirements, which vary significantly. This is educational overview content—always verify current rules with your compliance counsel and relevant regulators.

The SEC Marketing Rule establishes seven general prohibitions that apply to all investment adviser advertisements, including SEO-optimized web pages. Understanding these prohibitions shapes what your content can and cannot claim.

The Seven Prohibitions:

• Untrue statements of material fact or omissions that make statements misleading
• Unsubstantiated material claims
• Untrue or misleading implications about calculation or performance
• Discussion of potential benefits without fair disclosure of risks or limitations
• References to specific investment advice that isn't presented fairly
• Cherry-picked testimonials, endorsements, or case studies
• Misleading statements about SEC review or approval

What This Means for SEO Content: Every claim on your website must be substantiated before publication. If you write that your firm specializes in retirement planning for executives, you need documentation showing this focus in your client base or service offerings. Performance claims require specific methodologies and disclosures. Blog posts discussing market conditions must present balanced perspectives rather than solely bullish or bearish takes.

The rule doesn't prohibit marketing—it requires accuracy. You can still create comprehensive, authoritative content that ranks well. The constraint is honesty, not silence.

FINRA's communications framework applies to all broker-dealer member firms, establishing approval processes, content standards, and filing requirements for different communication types.

Retail Communication Standards: Any written or electronic communication distributed to more than 25 retail investors within a 30-day period qualifies as retail communication. Your website clearly meets this threshold. Retail communications must be approved by a registered principal before first use, and many must be filed with FINRA's Advertising Regulation Department.

Content Standards Under Rule 2210:

• Information must be fair and balanced
• No predictions or projections of investment performance
• No exaggerated or unwarranted claims
• Material facts cannot be omitted if omission makes statements misleading
• Comparisons must disclose material differences between products or services

Principal Approval Process: For SEO purposes, this means your compliance principal must review and approve new web pages, blog posts, and substantial content updates before publication. Build this review cycle into your content calendar—rushing compliance review creates bottlenecks and increases rejection risk.

Filing Requirements: Certain communications require filing with FINRA within 10 business days of first use. New member firms face additional pre-use filing requirements during their first year. Consult your compliance team on which content categories require filing for your specific firm.

Compliance constraints don't eliminate SEO opportunity—they shape the approach. In our experience working with investment firms, educational content and service explanation pages often outperform promotional content anyway, because they match how prospective clients actually search.

Educational Content Framework: Content explaining financial concepts, investment approaches, or planning strategies typically receives more regulatory flexibility than promotional material. A page explaining 'What Is a Concentrated Stock Position?' serves searcher intent, builds expertise signals, and avoids most advertising rule triggers—as long as it doesn't pivot to selling your diversification services without appropriate disclosures.

Service Pages That Work: Describe what you do, who you serve, and your process without unsubstantiated superlatives. 'We provide fee-only financial planning for technology executives' is factual and rankable. 'We deliver the best returns for tech executives' requires substantiation you likely cannot provide.

Team and Expertise Pages: Biographical information, credentials, and professional history are generally permissible with appropriate accuracy. These pages build E-E-A-T signals search engines prioritize for YMYL financial content.

The Disclosure Infrastructure: Build disclosure capability into your website architecture. Performance pages need calculation methodology disclosures. Testimonial pages (where permitted) need compensation and conflict disclosures. Rather than treating disclosures as obstacles, design them as user-experience elements that build trust.

Regulatory enforcement actions and examination deficiency letters reveal recurring patterns in investment firm marketing compliance failures. Avoiding these patterns protects both your firm and your search visibility—because content that gets pulled creates broken pages and lost rankings.

Performance Claims Without Methodology: Stating performance results without disclosing the calculation methodology, time period, or benchmark comparison violates both SEC and FINRA rules. If you cannot fully substantiate and disclose a performance claim, don't make it on your website.

Cherry-Picked Testimonials: The SEC Marketing Rule now permits testimonials and endorsements for RIAs under specific conditions, but cherry-picking only favorable reviews while suppressing negative ones violates the 'fair and balanced' requirement. Your testimonial selection must be representative, not curated for positivity.

Unsubstantiated Expertise Claims: Claiming specialization in a practice area without documentation to support that focus draws regulatory scrutiny. Before writing 'We specialize in...' ensure you have client demographics, service records, or other evidence that substantiates the claim.

Outdated Information: Websites with stale team bios (showing departed advisers), outdated AUM figures, or obsolete regulatory disclosures create compliance exposure. SEO maintenance must include compliance maintenance—quarterly content audits should check accuracy alongside performance metrics.

Missing Required Disclosures: Form ADV Part 2A must be available to prospective clients. Form CRS requirements apply to dual-registrants. State notice filing requirements vary. Missing these basics signals larger compliance gaps to examiners.

Effective investment firm SEO requires treating compliance review as a production step, not an afterthought. Firms that build compliance into their content workflow publish more frequently and face fewer revision cycles than those who create first and seek approval later.

Pre-Production Compliance Briefing: Before writing any new page or post, brief your compliance team on the topic, target keywords, and planned claims. They can flag issues early—before you've invested writing and design time in content that cannot be approved.

Draft Review Cycle: Submit complete drafts with source documentation for any claims. Include proposed disclosures positioned where they'll appear on the live page. Compliance reviewers can assess context better when seeing the full presentation.

Revision Tracking: Maintain version control showing compliance-requested changes. This documentation demonstrates good faith effort during examinations and helps train content creators on recurring issues.

Publication and Filing: For FINRA-member firms, document principal approval and complete required filings before or within required timeframes after publication. Maintain an advertising log as required by your firm's written supervisory procedures.

Ongoing Monitoring: Pages rank for evolving keyword sets over time. Monitor what queries bring traffic to each page—if a page begins ranking for terms implying claims it doesn't make, consider clarifying content to prevent misimpression. Also monitor for stale information requiring updates.

The goal is sustainable content production that serves both marketing and compliance objectives. Investment firms that treat these as opposing forces produce less content and face more friction. Firms that integrate the functions publish more, rank better, and sleep easier during examinations.