Methodology · Transparency Brief

The methodology behind every report.

A $400 compliance audit is only worth it if the analysis is defensible. This page documents exactly how your website is evaluated — what we read, what we cross-reference against your public filings, what we verify, and what every finding is grounded in.

The Core Question

Why a general-purpose AI
cannot do this.

It is a fair objection: if Claude or ChatGPT can read a webpage and know the Marketing Rule, what exactly are you paying for? The answer is four specific things a raw chat session cannot reproduce.

01 · DOMAIN PROMPT

A purpose-built regulatory prompt, not a chat session.

The analysis is driven by an instruction set written specifically for investment adviser websites. It encodes the severity policy — a missing Form CRS link, for instance, is treated as a blocker rather than a high-severity finding — the conditionality logic for when Form CRS and Reg S-P actually apply, the direction of Form ADV Item 5.L discrepancies, and a suppression rule that discards any finding that cannot quote the underlying page text.

A chat prompt will find surface issues. This system is tuned to find the issues an examiner would write up.

02 · FORM ADV CROSS-REFERENCE

Structured filing data that a chatbot does not have.

Every analysis ingests your Form ADV Item 5.L marketing declarations as structured data — which advertising practices your firm declared to the SEC it uses, and which it declared it does not. The system then reads your website to check whether the two are consistent, in both directions.

The asymmetry here is the signal: a chatbot cannot read your ADV as structured facts, only as text.

03 · TWO-PASS QA LAYER

Independent verification before a report leaves the system.

No report is delivered on the first pass. Every report passes through a deterministic integrity check (code, not AI) and an independent semantic review by a second model before it leaves the system.

This is the single largest thing you cannot reproduce by pasting a URL into ChatGPT.

04 · EVIDENCE GROUNDING

Every finding tied to exact text from your site.

Findings are not summaries. Each one is bound to a specific page, a specific quote, and a specific rule citation. A finding that cannot produce the underlying evidence is discarded, not softened. This is enforced structurally, not stylistically.

If a finding cannot be evidenced, it does not exist in the report.

Process

What happens between
your URL and the final report.

Every report moves through four stages. Each stage has a specific job, a specific input, and a specific output.

STAGE 01

Filing Intake

We load your firm's public Form ADV data — including Item 5.L marketing declarations, fee structures, services described, and AUM — as structured input the analysis can reason over.

Form ADV Item 5.L
STAGE 02

Website Capture

We crawl your public website, classify each page by type, and extract the text the analysis will read — bios, fee language, performance claims, testimonials, disclosures, third-party ratings.

Full Crawl Classification
STAGE 03

Regulatory Analysis

The captured site is evaluated against eight compliance domains and reconciled against your filings — surfacing misalignment, missing disclosures, and marketing practices that diverge from what was declared to the SEC.

8 Domains ADV Reconciliation
STAGE 04

QA & Delivery

Every report passes through a deterministic integrity layer and an independent semantic review before it is delivered. Reports that fail either pass are returned for revision, not sent.

Deterministic QA Semantic QA
Coverage

The eight compliance domains
every report covers.

Each domain carries its own set of specific examinations, anchored to the rule text and informed by recent SEC Risk Alerts and enforcement actions.

1

Testimonials & Endorsements

206(4)-1(b)

Client testimonials and third-party endorsements are examined for the specific disclosures the rule requires — whether the person is a client, whether compensation was provided, and whether material conflicts are disclosed.

  • Clear and prominent client/non-client disclosure
  • Cash and non-cash compensation disclosure
  • Material conflict of interest disclosure
  • Form ADV Item 5.L(1)(a) / (b) consistency
2

Performance Advertising

206(4)-1(d)

Any presentation of performance results is reviewed against the rule's structural requirements on net-of-fees, prescribed time periods, hypothetical performance, and the treatment of predecessor or related performance.

  • Net-of-fees presentation and related disclosures
  • Prescribed 1-, 5-, and 10-year time periods
  • Hypothetical performance audience restrictions
  • Related and predecessor performance conditions
3

Third-Party Ratings

206(4)-1(c)

Any use of third-party rankings, awards, or ratings on the site is checked for compliance with the rule's specific disclosures — the date, the period covered, and compensation paid to receive or publicize the rating.

  • Date of the rating and the period it covers
  • Identity of the third party
  • Compensation for the rating or its publication
  • Form ADV Item 5.L(1)(c) consistency
4

General Marketing Prohibitions

206(4)-1(a)

The rule's seven general prohibitions — including untrue statements, unsubstantiated claims, misleading implications, and cherry-picked references — are applied to superlatives, guarantees, and claims made across the site.

  • Unsubstantiated superlatives and guarantees
  • Misleading implication or inference
  • Materially misleading omissions
  • Cherry-picked specific recommendations
5

Form ADV Consistency

Form ADV Part 2A

The claims your website makes are reconciled against the text of your Form ADV — services offered, fee schedules, conflicts, types of clients, and assets under management — to surface material inconsistencies in either direction.

  • Services and strategies described
  • Fee structures and minimums
  • AUM and client-type consistency
  • Conflict-of-interest alignment
6

Regulatory Fundamentals

Form CRS / Reg BI

For firms serving retail clients, the site is checked for the visibility and availability of Form CRS, proper disclosures of fiduciary status, and the presence of required regulatory links — with conditionality applied based on retail-client status.

  • Form CRS prominence and accessibility
  • Fiduciary standard disclosure
  • IAPD / SEC linking and disclaimers
  • ADV Part 2A and 2B availability
7

Privacy & Cybersecurity

Regulation S-P

The public-facing elements of your Regulation S-P posture are reviewed — privacy notice availability, content intake forms, opt-out language, and the site's basic technical hygiene around data handling.

  • Privacy notice presence and scope
  • Contact and intake form data handling
  • Opt-out and choice language
  • HTTPS and basic transport security
8

Website Accessibility

ADA · WCAG 2.1 AA

Not a Marketing Rule domain, but included because accessibility suits against RIA sites have risen sharply. We scan for the WCAG 2.1 AA issues most commonly cited in complaints.

  • Text alternatives for non-text content
  • Keyboard navigation and focus visibility
  • Color contrast on critical UI elements
  • Form labels and screen-reader semantics
Deep Dive · Form ADV Item 5.L

Your filings already told the SEC
which marketing practices you use.

Form ADV Part 1A Item 5.L is a structured disclosure of how your firm advertises. Each line is a binary declaration: yes, we use testimonials; no, we do not present hypothetical performance; yes, we use third-party ratings. The most overlooked source of compliance exposure is the gap between those declarations and the actual content on your website.

We read Item 5.L as structured facts, not prose. The system ingests each declaration and then examines your site for the content that declaration implies — or for the content that declaration forbids.

The direction of the discrepancy matters. If your ADV declares you use testimonials but no testimonials appear on your site, the remediation is to update the filing, not to add content. If no testimonials are declared but endorsement-style language appears on a bio page, that is a different finding with a different remediation.

This is the single hardest check to reproduce manually. It requires parsing Part 1A, interpreting each Item 5.L sub-field against the Marketing Rule, and reading every page of the website with those sub-fields in hand as a live reference.

Getting the direction wrong is one of the easiest ways to produce a finding that makes an adviser more exposed, not less. The QA layer exists specifically to catch this.

Item 5.L declarations · your filing
5.L(1)(a) Testimonials Yes
5.L(1)(b) Endorsements No
5.L(1)(c) Third-party ratings Yes
5.L(1)(d) Past specific recommendations No
5.L(1)(e) Hypothetical performance No
5.L(1)(f) Predecessor performance No
· · ·
Cross-reference finding
Endorsement-style language appears on the "Team" page describing professional relationships that a reasonable reader would interpret as an endorsement, while Item 5.L(1)(b) declares endorsements are not used. Remediation references the filing, not the website.
Quality Assurance

Every report passes through
two independent reviews.

A single-pass AI analysis will produce findings that look correct and are not. The QA layer exists to catch what the analysis pass misses, and to reject reports that fail either review.

2
Review passes
15+
Integrity checks
100%
Reports reviewed
Pass 1 · Deterministic

Structural integrity, checked by code.

Code-enforced rules that an AI cannot negotiate with. If a report violates one, it does not ship — it is sent back for revision.

  • Scoring consistency Overall score must reconcile to the weighted average of category scores. Arithmetic errors are blockers.
  • Language policy enforcement Blocks words the system must never use — "violation," "non-compliant," "illegal." Findings are indications, not verdicts.
  • Citation validation Every regulatory citation is flagged for verification. A finding that leans on a misremembered rule section is caught here.
  • Severity policy rules Certain findings — e.g., a missing SEC disclaimer — cannot be rated Critical by policy. The rule is enforced, not suggested.
  • Finding-count sanity A report with fewer than five findings or more than fifteen is flagged. Outliers require explanation before delivery.
  • Style and register US English, consistent tense, no filler category weighting, coherent executive summary length.
Pass 2 · Semantic

Meaning and evidence, reviewed by an independent model.

A second, independent model reviews the generated report against the scraped site content. It is the check that catches the errors only another careful reader would see.

  • Evidence hallucination detection Every quoted passage must exist verbatim in the scrape. Findings built on invented evidence are rejected.
  • Categorization correctness Firm self-promotion miscategorized as a testimonial, a fee disclosure flagged under performance — these are caught and re-routed.
  • Double-count detection The same website text surfacing under two findings inflates risk. The QA pass merges or removes duplicates.
  • Conditionality enforcement Form CRS and Reg S-P findings are conditional on retail-client status. If status is not confirmed, the finding must say so.
  • Remediation direction check For Item 5.L discrepancies, the remediation must match the direction of the gap — update the filing, or update the site. Never both.
  • Missed-issue scan The reviewer reads the scrape independently and flags material issues the analysis pass did not surface. Reports with missed findings are regenerated.
A report is only delivered once it has passed both reviews cleanly. Anything less is sent back to the analysis stage for regeneration. The version you read is the version that survived.
Output

What a finding actually
looks like.

Every finding in your report carries the same structure — a category, a severity, a specific title, the evidence it is built on, the regulatory reference, and a concrete remediation. Here is a real finding from a generated report.

General Marketing Compliance High Risk
Title
Unsubstantiated "Unparalleled Results" claim on homepage
Description
The homepage headline states the firm delivers "Unparalleled Results in Traditional Brokerage and Investment Advisory." Under Rule 206(4)-1(a)(1), an advertisement may not include an untrue statement of material fact, or omit a material fact such that the advertisement is misleading. The phrase is an unsubstantiated superlative implying superior results without a supporting basis in fact.
Evidence
Homepage · "We Deliver Unparalleled Results in Traditional Brokerage and Investment Advisory With Our Trusted Expertise."
Regulatory reference
Rule 206(4)-1(a)(1) · General Prohibitions on Advertisements
Remediation
Remove or substantially revise the phrase "Unparalleled Results" to avoid implying superior or guaranteed performance. Replace with factual, substantiable descriptors that do not rely on comparative superlatives.
Specific

A titled issue on a named page, not a general category concern or a theme.

Evidenced

The exact text from your site that triggered the finding, quoted verbatim.

Actionable

A concrete remediation your CCO or web team can act on in a single sitting.

Honest Limits

What this report is not.

A credible methodology has to be clear about its boundaries. These are the things we do not do — and that no automated analysis should claim to do.

Not legal advice.

Findings are indications of areas that may warrant review. They are analytical, not legal opinions. Every finding should be reviewed by your firm's compliance counsel or Chief Compliance Officer before action.

Not affiliated with the SEC.

RIA Health Check is an independent service. It is not affiliated with, endorsed by, or sponsored by the U.S. Securities and Exchange Commission or FINRA. Public SEC data is used only as a cross-reference input.

Not a replacement for your CCO.

The report is a tool that compresses weeks of manual website review into a structured, evidence-based artifact. It is input into your compliance program, not a substitute for it.

Not a scan of gated content.

Only your public website is read — the surface that regulators, prospects, and the public already see. Client portals, intranets, and authenticated content are out of scope.

Ready When You Are

See what this methodology
finds on your site.

Start with a free scorecard to see your overall compliance risk and headline findings. When you are ready, the full report delivers the complete evidence, remediation, and cross-reference your CCO can act on.