FINRA Examinations: What They Request and How to Prepare Your Website Records

It arrives by email or mail — a FINRA examination notification letter. Your firm has been selected for a routine cycle examination, a cause examination triggered by a complaint, or a sweep examination targeting a specific compliance topic. Whatever the type, the letter includes a document request list, and somewhere on that list (usually buried in the middle) is a line item requesting your website records.

Here's what most firms discover at this point: they don't have website records. Not real ones, anyway. Maybe someone took a screenshot of the homepage once. Maybe there's a PDF of the privacy policy saved in a shared drive. But a systematic, timestamped, integrity-verified archive of every page version? Most firms don't have that. And FINRA examiners know it.

The examination notification typically gives you 2-4 weeks to produce the requested documents. If you have an automated archiving system, pulling website records takes five minutes. If you don't, your compliance team is about to have a very long couple of weeks.

FINRA examiners reviewing website compliance focus on several areas. First, they compare your current website against your filed disclosures — ADV, CRS, fee schedules — looking for discrepancies. If your website says 'fees starting at 0.5%' but your ADV says 1%, that's a finding.

Second, they look at historical changes. Did you update fee disclosures without proper notice? Did you add testimonials without the required disclaimers when the Marketing Rule took effect? Did you remove risk warnings from a product page? Historical website archives answer these questions — for better or worse.

Third, they check the basics: is your BrokerCheck link prominent? Are required disclosures present? Is your Form CRS accessible? These might seem like trivial items, but they're easy findings for examiners, and firms get cited for them regularly.

The examiner doesn't need to be right about a violation to make your life difficult. They just need to ask a question you can't answer with documentation. 'What did your fee disclosure page say in September 2025?' is a simple question. Without an archive, it's unanswerable.

Firms with automated website archiving handle examination requests like this: they log into their archiving platform, search for the date range specified in the examination letter, download the compliance certificates for the relevant pages, and send them to the examiner. Total time: under an hour.

Each certificate contains the full-page screenshot, SHA-256 hash, capture timestamp, and metadata. The examiner can verify the hash independently. There's no ambiguity about what was displayed and when. The website portion of the examination becomes a non-event — a box that gets checked without friction.

Firms without archiving respond differently: they ask their web developer if there are any old versions saved somewhere, check the Wayback Machine (which probably has incomplete captures), ask marketing if anyone saved screenshots of old pages, and ultimately submit whatever fragments they can find with a note explaining that they don't have comprehensive records. That note, by itself, is a recordkeeping deficiency.

FINRA fines for recordkeeping violations under Rule 17a-4 can reach $150,000 per violation. In 2024, FINRA issued over $89 million in total fines for recordkeeping deficiencies. Many of these involved firms that simply didn't have adequate systems for retaining business communications — including website content.

Beyond fines, examination findings create a compliance record that follows your firm. Future examinations will scrutinize the areas where you had prior findings more heavily. A recordkeeping deficiency in one examination means increased scrutiny of your records in the next one. It's a cycle that's much easier to prevent than to break.

At $19/month, automated website archiving with VaultShot costs less than 0.013% of the maximum per-violation fine. That's not a sales pitch — it's arithmetic.