On September 4, 2025, the SEC announced that it had settled charges (Order) against an investment adviser whose clients are primarily individuals. The Order enumerated several violations of the Investment Advisers Act of 1940 (Advisers Act) relating to marketing; recordkeeping; implementation of compliance policies and procedures; and annual compliance reviews. Specifically, the misconduct involved violative statements in advertisements appearing on the firm’s public website, as well as the failure to retain archived versions of the site. Despite the SEC’s focus under Chair Paul S. Atkins on actual fraud and investor harm, the Order is a reminder that the SEC will still pursue enforcement efforts for technical breaches of compliance obligations even when there is no apparent harm to investors. This article summarizes the Order and provides further insights from industry experts about proper industry practices to comply with the substantiation requirements under Rule 206(4)‑1 of the Advisers Act and to properly retain archived versions of firms’ websites. For coverage of other recent SEC enforcement actions under Atkins, see “SEC Fines Sponsor for Overcharging PE Funds Via Improperly Applied Management Fee Offsets” (Oct. 2, 2025); and “SEC Enforcement Action Raises Potential Materiality Threshold for Conflicts of Interest” (Jul. 24, 2025).