Archiving requirements matcher

Pick the firm type and the channels your people use, and get each channel’s retention period, storage terms, review duty and the capture to ask a vendor about, as one sheet to copy or print. The SEC email retention requirements for advisers and the FINRA archiving requirements for broker-dealers differ in what they reach and how they store it; Microsoft Teams archiving, texts and social posts are on the same sheet.

Pre-filled with an example: a one-adviser firm registered with the SEC that uses email, texts and LinkedIn. Change the firm type or tick the channels your people actually use.

Firm type

State-registered advisers follow their state's rules, which this tool does not cover.

Keep each captured record at least

5 years

The minimum the rules set for what is on these 3 channels. Advisers count from the end of the fiscal year, not from the date of the message or post.

17 CFR 275.204-2(a)(7), (e)(1); 17 CFR 275.204-2(a)(11), (e)(3)(i)

SEC-registered investment adviser: Email, Texts (SMS), Social media

Email

Keep
Written communications on advice, funds or securities, orders and performance5 years
In an easily accessible place, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(7), (e)(1)
Store
Electronic storage
Arrange and index the records for easy retrieval; provide promptly a legible, true and complete copy; separately store a duplicate copy; safeguard them from loss, alteration or destruction; limit access to authorized personnel and the Commission. The rule names no WORM format and no audit trail for advisers.
17 CFR 275.204-2(g)(1)-(3)
Review
No FINRA review rule
FINRA Rule 3110 binds member firms, not a stand-alone adviser. Rule 206(4)-7(a) requires written policies and procedures reasonably designed to prevent violations of the Advisers Act; a message-review procedure sits there.
17 CFR 275.206(4)-7(a)
Capture to ask a vendor about
Capture at the mail system (journaling) for every mailbox, so a message is kept even if the sender deletes it.
Ask: Which mail systems does it journal from, and are shared mailboxes and aliases included?
Tools that cover it
Email archiving software compared Multi-channel archives: Smarsh alternatives

SMS and MMS texts

Keep
Written communications on advice, funds or securities, orders and performance5 years
In an easily accessible place, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(7), (e)(1)
Store
Electronic storage
Arrange and index the records for easy retrieval; provide promptly a legible, true and complete copy; separately store a duplicate copy; safeguard them from loss, alteration or destruction; limit access to authorized personnel and the Commission. The rule names no WORM format and no audit trail for advisers.
17 CFR 275.204-2(g)(1)-(3)
Review
No FINRA review rule
FINRA Rule 3110 binds member firms, not a stand-alone adviser. Rule 206(4)-7(a) requires written policies and procedures reasonably designed to prevent violations of the Advisers Act; a message-review procedure sits there.
17 CFR 275.206(4)-7(a)
Capture to ask a vendor about
Capture of the firm's numbers at the carrier, or a business texting app that gives each person a second number.
Ask: Which carriers does it capture from, and does it cover texts sent from a person's own phone?
Apple’s words: “SMS and MMS are carrier-provided services.” A carrier capture can reach them; it cannot reach iMessage.
Tools that cover it
Text message archiving compared FINRA-compliant texting compared

Keep
Written communications on advice, funds or securities, orders and performance5 years
In an easily accessible place, counted from the end of the fiscal year during which the last entry was made; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(7), (e)(1)
Posts and pages that are advertisements5 years
A copy of each one, counted from the end of the fiscal year during which the adviser last published or otherwise disseminated it; the first 2 years in an appropriate office of the investment adviser.
17 CFR 275.204-2(a)(11), (e)(3)(i)
Store
Electronic storage
Arrange and index the records for easy retrieval; provide promptly a legible, true and complete copy; separately store a duplicate copy; safeguard them from loss, alteration or destruction; limit access to authorized personnel and the Commission. The rule names no WORM format and no audit trail for advisers.
17 CFR 275.204-2(g)(1)-(3)
Review
No FINRA review rule
FINRA Rule 3110 binds member firms, not a stand-alone adviser. Rule 206(4)-7(a) requires written policies and procedures reasonably designed to prevent violations of the Advisers Act; a message-review procedure sits there.
17 CFR 275.206(4)-7(a)
Capture to ask a vendor about
Capture through each network's interface of posts, comments and direct messages, from the firm's page and each person's business profile.
Ask: Which networks and which account types (company page, personal profile) does it capture, and does it keep edited and deleted posts?
Tools that cover it
Social media archiving compared

Stipple engraving of an envelope, a phone, a laptop and a postcard each on a card before a box

Rule 204-2, 17a-4 and 3110 at a glanceCard 01

Adviser written communications5 years
17 CFR 275.204-2(a)(7), (e)(1)
Of which in an appropriate office of the adviserfirst 2 years
17 CFR 275.204-2(e)(1)
Adviser advertisements, from the year last disseminated5 years
17 CFR 275.204-2(e)(3)(i)
Adviser storage: indexed, duplicate copy, safeguarded
17 CFR 275.204-2(g)
Broker-dealer communications3 years
17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09
Of which in an easily accessible placefirst 2 years
17 CFR 240.17a-4(b)
Broker-dealer storage: audit trail or non-rewriteable, non-erasable
17 CFR 240.17a-4(f)(2)(i)
Broker-dealer review by a registered principal, in writing
FINRA Rule 3110(b)(4)

From the eCFR text of Rules 204-2 and 17a-4 (as of October 20, 2026) and FINRA’s rulebook, read October 22, 2026. The same periods drive the retention calculator.

What it computes

For each channel you tick, the matcher answers four questions a vendor demo rarely answers straight: how long the rules keep what is said there, how it must be stored, who has to review it, and what kind of capture can reach it. The first three come from the rule text; the fourth is the question to put to the vendor. The result is a sheet you can paste into an email to every archive you are pricing, so each one answers the same list.

Advisers: written communications on advice, funds, orders and performance, plus advertisements
17 CFR 275.204-2(a)(7), (a)(11)
Broker-dealers: all communications relating to the business, plus retail communications
17 CFR 240.17a-4(b)(4); FINRA Rule 2210(b)(4)
Storage conditions differ: 204-2(g) for advisers, 17a-4(f) for broker-dealers
17 CFR 275.204-2(g); 17 CFR 240.17a-4(f)

The two rulebooks reach different things. An adviser’s duty under Rule 204-2 covers written communications on four subjects, which is narrower than a broker-dealer’s duty to keep all communications “relating to its business as such.” The storage rules differ more: the 17a-4(f) conditions, with their audit trail or non-rewriteable format, bind broker-dealers only. An adviser’s archive meets 204-2(g) instead, which names indexing, prompt production, a separate duplicate copy and safeguards, and no WORM format.

The periods are the ones the books and records retention calculator uses, read from the same data, so the two tools always agree; use the calculator for a dated keep-until on one record. A channel you do not allow still matters if people use it anyway: that gap is what the SEC’s off-channel cases were about, and the off-channel policy builder writes the rule for your people. State-registered advisers follow their state’s rules, which the tool does not read.

Worked example

Take the tool’s default: a one-adviser firm that emails clients, texts them from the adviser’s phone and posts on LinkedIn. Registered with the SEC as an adviser, its client emails and texts about a recommendation are written communications under Rule 204-2(a)(7), kept under 204-2(e)(1). Its LinkedIn posts that offer its services are advertisements, kept under 204-2(e)(3)(i); a LinkedIn message about a client’s portfolio is a written communication again. The same three channels at a broker-dealer fall under Rule 17a-4(b)(4) and, for the posts, FINRA Rule 2210(b)(4).

Email, texts and LinkedIn at an adviser and at a broker-dealer

Retention periods the matcher returns for three channels under each firm type
Channel	Firm type	What is kept	Keep at least	Rule
Email	Adviser, Rule 204-2	Written communications on advice, funds or securities, orders and performance	5 years	17 CFR 275.204-2(a)(7), (e)(1)
Texts (SMS)	Adviser, Rule 204-2	Written communications on advice, funds or securities, orders and performance	5 years	17 CFR 275.204-2(a)(7), (e)(1)
Social media	Adviser, Rule 204-2	Written communications on advice, funds or securities, orders and performance	5 years	17 CFR 275.204-2(a)(7), (e)(1)
Social media	Adviser, Rule 204-2	Posts and pages that are advertisements	5 years	17 CFR 275.204-2(a)(11), (e)(3)(i)
Email	Broker-dealer, Rule 17a-4 and FINRA	Communications relating to the business as such	3 years	17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09
Texts (SMS)	Broker-dealer, Rule 17a-4 and FINRA	Communications relating to the business as such	3 years	17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09
Social media	Broker-dealer, Rule 17a-4 and FINRA	Communications relating to the business as such	3 years	17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09
Social media	Broker-dealer, Rule 17a-4 and FINRA	Retail and institutional communications	3 years	FINRA Rule 2210(b)(4)(A)

Generated by the matcher from the retention calculator's rule data

Read the periods with their start points. The adviser’s five years run from the end of the fiscal year of the last entry, so a text sent in March 2026 by a firm with a December year end is kept until at least December 31, 2031. The broker-dealer’s three years have no start day in the rule, so a firm counts from the record’s own date unless its written procedures count from later. Either way, what decides the archive is whether it captures the texts at all: the texting tools compared for FINRA firms are read on that first.

The rule text

Four sentences carry most of the sheet: what an adviser keeps, what a broker-dealer keeps, how a broker-dealer stores it, and who reviews it.

The third and fourth sentences bind FINRA member broker-dealers. An adviser’s storage terms are in Rule 204-2(g), which asks for indexing, prompt production, a separately stored duplicate copy and safeguards against loss, alteration or destruction. The guide to FINRA Rule 3110 covers what a written review record has to show.

Where the rule says so

Every channel in the matcher with the paragraphs it rests on, for an adviser and for a broker-dealer. Open a row to read them. The full text is on the eCFR for Rule 204-2 and Rule 17a-4, and in FINRA’s rulebook for Rule 3110 and Rule 2210.

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

SMS and MMS texts

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

Apple’s words: “SMS and MMS are carrier-provided services.” A carrier capture can reach them; it cannot reach iMessage.

iMessage

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

Apple sends iMessages between Apple devices over Wi-Fi or cellular data, not through the carrier's text service, so a carrier capture of SMS does not include them.

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

The SEC named WhatsApp in its May 2023 off-channel release on HSBC and Scotia.

Microsoft Teams or Slack

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

Rule 204-2(a)(7) names communications the adviser sends and receives on four subjects; it does not name internal chat. Settle how your firm treats internal threads with your compliance counsel.

Rule 17a-4(b)(4) includes inter-office memoranda and communications, and Rule 3110(b)(4) names internal communications for review.

Zoom chat

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

This sheet covers what is written in Zoom. Whether a call recording must be kept is not answered by the sentences quoted on this page; ask your compliance counsel.

LinkedIn, X or Facebook

Keep, adviser: Written communications on advice, funds or securities, orders and performance, 5 years. 17 CFR 275.204-2(a)(7), (e)(1)

Keep, adviser: Posts and pages that are advertisements, 5 years. 17 CFR 275.204-2(a)(11), (e)(3)(i)

Keep, broker-dealer: Communications relating to the business as such, 3 years. 17 CFR 240.17a-4(b)(4); FINRA Rule 3110.09

Keep, broker-dealer: Retail and institutional communications, 3 years. FINRA Rule 2210(b)(4)(A)

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Review by a registered principal. FINRA Rule 3110(b)(4), 3110.07

Review, broker-dealer: Approval before use. FINRA Rule 2210(b)(1)(A), (b)(1)(D)(ii), (b)(2)

FINRA's Regulatory Notice 10-06: a firm “must first ensure that it can retain records of those communications” before its people use a social site for business.

The firm's website

Keep, adviser: Posts and pages that are advertisements, 5 years. 17 CFR 275.204-2(a)(11), (e)(3)(i)

Keep, broker-dealer: Retail and institutional communications, 3 years. FINRA Rule 2210(b)(4)(A)

Store, adviser: Electronic storage. 17 CFR 275.204-2(g)(1)-(3)

Store, broker-dealer: Electronic recordkeeping system. 17 CFR 240.17a-4(f)(2), (f)(3)(v); FINRA Rule 4511(c)

Review, adviser: No FINRA review rule. 17 CFR 275.206(4)-7(a)

Review, broker-dealer: Approval before use. FINRA Rule 2210(b)(1)(A), (b)(1)(D)(ii), (b)(2)

In the first year of FINRA membership, retail communications on a generally accessible website are filed with FINRA at least 10 business days before first use (Rule 2210(c)(1)(A)).

Storage is a separate purchase for some firms. A broker-dealer that keeps its own records rather than relying on an archive’s storage can read the SEC 17a-4 compliant storage comparison against the two modes above; the guide to FINRA Rule 2210 covers approval and filing for the posts and pages on the sheet.

Archiving requirements matcher