FINRA-Compliant CRM: The Rule-by-Rule Checklist and Vendor Questions
FINRA-compliant CRM, in short: no CRM is FINRA compliant on its own — FINRA certifies no software. A compliant setup keeps communications for at least three years (SEC Rule 17a-4), six for records with no other period (FINRA 4511), five for RIAs (SEC Rule 204-2), in WORM storage or with a full audit trail, and proves principal review (FINRA 3110).
More on this topic: Best CRM by industry and team, every guide in one place.
This page is the checklist version: each rule, what it asks of your software, which part of your stack usually carries it, and the questions to put to a vendor in writing. If you want the ranked shortlist of CRMs, that lives in our guide to the best CRM for financial advisors. This is a summary for choosing software, not legal advice — your compliance officer has the final word.
Key takeaways
- Compliance is a property of the setup, not the product. The CRM, the communications archive and your supervisory procedures share the work.
- Broker-dealers: communications kept 3+ years, the first 2 easily accessible (17a-4(b)(4)); other FINRA records 6 years where no period is set (4511(b)).
- RIAs: advice-related written communications kept 5 years from the end of the fiscal year of the last entry (204-2(e)(1)).
- Electronic records need a complete time-stamped audit trail or non-rewriteable, non-erasable storage, plus a backup and export in a usable format (17a-4(f)(2)).
- Supervision must be evidenced: who reviewed what, when and what they did — opening a message is not a review (3110.07).
- Regulation S-P now requires an incident response program and oversight of service providers — which includes your CRM vendor.
Is there such a thing as a FINRA-compliant CRM?
No — not as a certified product. FINRA writes rules for member firms, not for software vendors, so the obligation to make, keep and supervise records stays with the firm whatever it buys. When a vendor says "FINRA compliant", it means its product can play a part in a setup that meets the rules. Your job is to find out which part.
The setup has three layers: the CRM holds client and account records; the archive (Smarsh, Global Relay and similar) captures communications in tamper-proof storage with a review queue; your written supervisory procedures say who reviews what.
What does a FINRA-compliant CRM setup need? The rule-by-rule checklist
A compliant setup captures every business communication, keeps it for the required period in a form nobody can quietly change, lets a principal review it with evidence, and produces it on request.
| Rule | What it requires | What to check | Usually carried by |
|---|---|---|---|
| SEC 17a-4(b)(4) | Originals of communications received and copies of those sent, relating to the business — 3 years, first 2 easily accessible | Every channel the CRM can send through is captured | Archive (journaled from email and SMS provider) |
| SEC 17a-4(f)(2)(i) | Electronic records kept with a complete time-stamped audit trail of modifications and deletions, or in non-rewriteable, non-erasable format | Can a note or email be edited or deleted without a trace? | Archive; CRM only if its audit trail is complete |
| SEC 17a-4(f)(2)(iv)–(v) | Download records in a human-readable and a reasonably usable electronic format; keep a backup system or redundancy | Export by client, user and date; backup arrangements | Archive and CRM |
| SEC 17a-4(i) | A third party holding records files a written undertaking that the records belong to the firm and will be surrendered on request | Will the vendor sign the undertaking? | Archive vendor (ask your CRM vendor too) |
| FINRA 4511 | Make and preserve required records; 6 years where no period is specified; 17a-4-compliant format | Retention settings that cannot be shortened by a user | Archive and CRM |
| FINRA 4512(a) | Customer account information, including the associated person responsible and a trusted contact person (reasonable efforts) | Fields for trusted contact and responsible rep on every account | CRM |
| FINRA 3110(b)(4), .07, .08 | Principal review of correspondence, evidenced in writing — reviewer, item, date, action; delegation allowed, responsibility stays | A review queue that logs who, what, when and the outcome | Archive |
| FINRA 2210(b)(1), (b)(4) | Principal approval of retail communications before use; records of first and last use and the approver | Approval workflow for newsletters and campaigns | Archive or a marketing-review tool |
| SEC 204-2(a)(7), (e), (g) | RIAs: advice-related written communications kept 5 years; electronic records indexed, protected from alteration, access limited | Indexing, role permissions, alteration protection | Archive and CRM |
| Regulation S-P (2024 amendments) | Incident response program; notify affected individuals within 30 days; oversee service providers | Breach notice terms in the vendor contract; security review | Firm policy, applied to every vendor |
Rule text checked in October 2026 against FINRA's rulebook (4511, 4512, 3110, 2210), the Code of Federal Regulations (17 CFR 240.17a-4, 17 CFR 275.204-2) and the SEC's Regulation S-P fact sheet. Not legal advice.
Retention and format: the part most CRMs cannot do alone
Rule 17a-4(f)(2) gives broker-dealers two routes for electronic records: a complete, time-stamped audit trail of every modification and deletion, or non-rewriteable, non-erasable (WORM) storage. Either way the system must verify storage, export in human-readable and usable formats, and keep a backup.
An ordinary CRM edit history rarely keeps the full prior content of a note or email, and an administrator can often delete the record outright — which is why most firms keep communications in an archive.
Account records: what the CRM itself must hold
FINRA Rule 4512 lists what a member keeps for each account, including the associated person responsible for it, the sign-off of whoever accepted it and a trusted contact person aged 18 or older (the firm must make reasonable efforts to obtain one). This is CRM territory: check these are structured, reportable fields.
Supervision: evidence, not access
Rule 3110(b)(4) requires reviews of correspondence and internal communications to be done by a registered principal and evidenced in writing. The supplementary material (.07) is specific: the evidence must identify the reviewer, the communication, the date and any action taken, and merely opening a message is not a review. Under .08, a supervisor may delegate some review functions to unregistered staff but remains responsible. Most CRMs have no review queue at all, which is the main reason the archive vendor matters as much as the CRM.
Marketing sends: Rule 2210
A message sent to more than 25 retail investors within 30 calendar days is a retail communication that a principal must approve before use. A newsletter sent from a CRM's email tool is caught by this, so the campaign feature needs an approval step or should be switched off.
Data security: Regulation S-P
The SEC's 15 May 2024 amendments to Regulation S-P require broker-dealers, investment advisers and other covered institutions to run an incident response program, notify affected individuals within 30 days of becoming aware of unauthorised access to sensitive customer information, and oversee service providers. Larger firms had 18 months from Federal Register publication to comply, smaller ones 24. Your CRM vendor is a service provider, so its breach terms belong in your contract review.
Which parts does the CRM handle, and which does the archive?
The CRM handles relationships, account data and workflow; the archive handles communications retention and supervision. Split the checklist this way before you evaluate anything, so you test each vendor on the job it is actually doing.
| Job | CRM | Communications archive | Email / phone provider |
|---|---|---|---|
| Household and account records (4512) | Primary | — | — |
| Review cycles and service tasks | Primary | — | — |
| Capture of email and texts | Logs activity only | Primary | Journals to archive |
| WORM or full audit trail (17a-4(f)) | Rarely | Primary | — |
| Principal review queue (3110) | Rarely | Primary | — |
| Retail communication approval (2210) | Sometimes | Often | — |
| Change history on client data | Primary | — | — |
| Export for an exam | Client data | Communications | — |
What questions should you ask a CRM vendor about FINRA compliance?
Ask for written answers that map to specific rules, rather than accepting a "compliant" badge.
- Which channels does your product send through (email, SMS, WhatsApp, voice), and how is each one captured by an archive? Name the archive vendors you deliver to.
- Is your synced email a copy or a view? What happens to synced messages when a user disconnects or leaves?
- Does your audit trail record the previous value of every edit to notes, activities and account fields — and can an administrator alter or delete it?
- How long is audit history kept, and can retention be set to six years or longer?
- Can you export records by client, user and date range in a format an examiner can read?
- Will you sign a third-party undertaking of the kind Rule 17a-4(i) describes, if you hold required records?
- Is there an approval step for mass emails, and does it log the approver and date?
- How quickly will you notify us of a breach, and what does your contract say? Regulation S-P puts a 30-day customer notice clock on us.
- What happens to our data at contract end — export format, deletion timing, and whether retention obligations can be honoured after we leave?
How does a CRM-integrated wealth management platform fit?
A CRM-integrated wealth management setup puts the advisor CRM at the centre as the client and household record, with portfolio management, custodial data, financial planning and the archive connected to it. Integration matters because every system you re-key into is another place records can drift. Wealthbox's integrations page, for example, lists portfolio tools such as Orion, Black Diamond, Tamarac, Envestnet and Addepar; custodial platforms including Charles Schwab, Fidelity and Altruist; and planning tools such as eMoney, MoneyGuide and RightCapital (Wealthbox integrations).
An integration that pulls account data into the CRM does not make it an archive, and portal messages may need capturing too.
| Advisor CRM | Published price | Billing basis | Compliance note |
|---|---|---|---|
| Redtail CRM | Launch $39, Growth $59 per user/mo | Annual ($45 / $65 monthly); Launch max 5 users | Sells Redtail Email, which it says archives client email; price on request |
| Wealthbox | Basic $59, Pro $75, Premier $99 per user/mo | Per user; billing term not stated on the page | Mail sync is not an archive — pair with one |
| Salesforce Financial Services Cloud | $325–$700 per user/mo | Billed annually | Configurable; archiving through partners |
Prices checked on the vendors' pricing pages in October 2026 (Redtail, Wealthbox, Salesforce). Archive vendors such as Smarsh and Global Relay quote privately — check current pricing with them.
Where do general CRMs and marketing tools fit?
General CRMs and marketing platforms fit in front of the system of record — prospect lists, seminar sign-ups, booking discovery meetings — and only where your compliance team has confirmed that every message they send reaches the archive and, for retail communications, has been approved. The SEC's off-channel enforcement sweep, which began with charges against 15 broker-dealers and one affiliated adviser and more than $1.1 billion in combined penalties (SEC release 2022-174), is the reason to treat every sending channel as in scope.
Scalry is a marketing and sales platform, not a books-and-records system. It keeps a workspace audit log with before-and-after values for a curated set of records, kept for 365 days by default — but edits to contacts and messages are not in that field history, messages and notes can be deleted, and there is no WORM storage, no supervisory review queue, no pre-approval workflow for retail communications and no connector to an archive. Regulated firms should use it, if at all, only for front-of-funnel work their compliance team has signed off.
How do you get an existing CRM setup exam-ready?
List every sending channel in every tool and confirm each is captured or switched off; send a test message from the CRM and find it in the archive's review queue; lock retention to the longest period that applies; report on accounts missing 4512 fields; and run a mock export for one client across CRM and archive.
For the broader rollout plan, our 30-day CRM implementation checklist covers the data and adoption side.
Frequently asked questions
What is a FINRA-compliant CRM?
It is a CRM used inside a setup that meets SEC and FINRA recordkeeping and supervision rules — usually by pairing it with a communications archive. FINRA does not certify software, so the label describes how a product is used, not an approval.
Does FINRA approve or certify CRM software?
No. FINRA's rules apply to member firms. A vendor can support your compliance by capturing communications, keeping audit trails and signing undertakings, but the obligation stays with the firm.
How long must a broker-dealer keep client emails?
At least three years, the first two in an easily accessible place, under SEC Rule 17a-4(b)(4). FINRA Rule 4511 sets six years for FINRA records with no other specified period. Firm policy or state rules may require longer.
Is a CRM audit log enough for SEC Rule 17a-4?
Usually not. Rule 17a-4(f)(2) requires a complete time-stamped audit trail of every modification and deletion, or non-rewriteable storage, plus verification, export and backup. Most CRM logs record field changes and can be deleted with the record.
What is a CRM-integrated wealth management tool?
A setup where the advisor CRM is the household record and portfolio management, custodial data, planning software and the archive connect to it, so data is not re-keyed. Redtail, Wealthbox and Salesforce Financial Services Cloud are common centres.
Do RIAs have to follow FINRA rules for their CRM?
SEC-registered investment advisers follow SEC Rule 204-2 instead: advice-related written communications kept five years, electronic records indexed and protected from alteration. Dual registrants follow both sets.
If you only need the marketing layer in front of your system of record, test it once your compliance team has approved the channels. You can rebuild one real campaign inside Scalry before moving anything else.
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