The Disclosures Your RIA Website Needs, and Where to Put Them

A polished advisor website can still fail a compliance review if the required disclosures are missing or buried. The good news is that the core list is short and predictable. Get these in place and you have covered most of what an examiner looks for on a public site. Below is what each one is, where it usually lives, and a placement checklist you can hand to whoever maintains your site.

Your Form ADV brochure

Registered advisers deliver a written brochure, Form ADV Part 2A, that describes services, fees, conflicts, disciplinary history, and more. Federal rules focus on delivering it to clients rather than posting it, but making it easy to find on your website is a widely used practice and saves back-and-forth with prospects. A footer link to the current PDF works well. Many firms also link to their public record on the SEC's Investment Adviser Public Disclosure site, adviserinfo.sec.gov, so visitors can verify registration themselves.

Keep the version current. An outdated brochure linked from your footer is a small detail an examiner will notice. Build a step into your annual amendment process to swap the file.

Form CRS, if you serve retail investors

Firms that work with retail investors prepare a short client relationship summary, Form CRS. Unlike the brochure, Form CRS has an explicit website requirement: if your firm has a public website, the current relationship summary must be posted there in a location and format that is easy for retail investors to access. In practice that usually means a clearly labeled link in the footer, next to the brochure. It should open the document directly rather than sending people through several clicks.

Accurate registration language

How you describe your registration matters. You are registered with the SEC or a state, and you cannot imply that registration is an endorsement, an approval, or a mark of skill. The Advisers Act specifically prohibits representing that a government agency has sponsored, recommended, or approved you. Skip phrases that suggest the regulator vouches for you. A plain, correct statement of your registration status is what you want, and many firms add a short line noting that registration does not imply a certain level of skill or training.

Disclosures next to testimonials and ratings

If your site features client testimonials, endorsements, or third-party ratings, the disclosures those require need to sit with them, visibly. For testimonials and endorsements, that is client status, compensation, and material conflicts. For ratings, it is the date, the period covered, the source, and whether you paid to be included. This is one of the most common gaps examiners cite, so treat the disclosure as part of the design, not an afterthought. Our guide on client testimonials goes deeper.

Performance disclosures

If you show performance anywhere, it brings its own disclosure requirements, including net-of-fee presentation and standard time periods. Those disclosures belong with the numbers. Many firms simplify by keeping performance off public pages altogether.

A privacy policy

Advisors handle sensitive personal and financial information. Regulation S-P governs how you protect client information and deliver privacy notices to clients. Separately, if your website collects personal information through a contact form, scheduling tool, or analytics, a posted website privacy policy is expected, and some state laws, including California's, require one. Make sure the policy describes what your site actually collects, including cookies and any third-party tools.

If you are dually registered or affiliated with a broker-dealer

Broker-dealer rules add their own items. FINRA requires member firm websites aimed at retail investors to include a readily apparent reference and link to BrokerCheck, and many broker-dealers apply similar standards to their representatives' sites. Your broker-dealer's compliance team will usually have required language and an approval process for the entire site.

If you are state-registered

Smaller advisers registered with one or more states follow state advertising and disclosure rules. Many states build on model rules from the North American Securities Administrators Association, and some have specific expectations for websites, such as identifying the states where you are registered or noting that you may only transact business where you are properly registered or exempt. Because the details differ, check the rules for each state where you are registered, and revisit them when you add a new state.

Make disclosures readable

A disclosure only does its job if people can read it. Tiny gray text on a gray background, a disclosure hidden behind a hover state, or a line that disappears on mobile all undercut the point. Use a readable font size, strong contrast, and plain language. Check every disclosure on a phone, since that is where many prospects will first see your site. Good design and good disclosure are not in tension. A clean, consistent disclosure style can look deliberate and professional.

Keep it current

Disclosures go stale quietly. The brochure gets amended, a rating expires, a testimonial giver stops being a client, or a new state registration adds a requirement. Tie a website review to the events that already happen in your firm: your annual Form ADV amendment, any new marketing campaign, and any change in registrations. Keep a dated copy of each version of the site so you can show what was live and when.

A note on where things live

Most of these belong in a consistent, reachable place, and the footer is the conventional home for brochure, Form CRS, privacy policy, and general disclosures. Testimonial, rating, and performance disclosures are the exception. Those go right where the testimonial, rating, or number appears, because the point is that a reader sees them at the same moment.

Placement checklist

• ☐ Form ADV Part 2A. Current PDF linked from the footer on every page.
• ☐ Form CRS. Posted on the site and linked prominently, if you serve retail investors.
• ☐ Public record link. Link to your firm's page on adviserinfo.sec.gov, often in the footer.
• ☐ Registration statement. Accurate wording in the footer or disclosures page, with no implied endorsement.
• ☐ Testimonial disclosures. Directly beside each testimonial or endorsement.
• ☐ Rating disclosures. Directly beside each badge or rating.
• ☐ Performance disclosures. With the figures, or remove the figures.
• ☐ Privacy policy. Linked from the footer and from any form that collects personal information.
• ☐ BrokerCheck link. If you are dually registered or your broker-dealer requires it.
• ☐ State notices. Any state-specific language your registration states require.

Build these in once and they quietly do their job on every page. Leave them out and even a beautiful site carries avoidable risk. For the content side, pair this with our SEC Marketing Rule website checklist. We build these placements into every site for RIAs and fee-only planners from the first wireframe.

This article is general information, not legal or compliance advice. Confirm any specific requirement with your firm's CCO or compliance counsel before you publish.