In my opinion, it’s the website.

With the SEC’s scrutiny of Marketing Rule compliance, I believe the SEC is closely scrutinizing Forms ADV filed by RIAs, and to the extent that RIAs indicate they are referencing testimonials, endorsements, third-party ratings, predecessor performance, hypothetical performance, or specific investment recommendations in their marketing materials, this gives the SEC an impetus to review the adviser’s marketing materials.

The marketing piece most easily accessible to the SEC is the RIA’s website, the address to which is also listed on the Form ADV.

Read more here.