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Comma Compliance

Web & Content Publishing

Your advisers are writing newsletters.

Are those posts in your archive?

Substack newsletters from registered representatives are retail communications under FINRA Rule 2210. Comma captures and archives them automatically — no manual exports, no workarounds — into the same tamper-proof archive as your other channels.

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Comma Compliance dashboard showing adviserfirm.substack.com monitored via Substack / RSS — daily scans, recent scan history, and pages changed.

The regulatory backdrop

A registered investment adviser publishing a Substack newsletter is generating written communications that must be retained under Rule 204-2 of the Investment Advisers Act. A registered representative doing the same is producing a retail communication under FINRA Rule 2210. Either way, the obligation follows the content, not the platform.

The challenge

Most archiving vendors focus on messaging apps and leave publishing platforms like Substack outside the archive entirely. If an examiner requests all written communications for a given period, a Substack newsletter from that period is responsive — whether or not it was ever captured.

How Comma closes it

Comma captures Substack newsletters automatically through an authenticated connection. Text, metadata, and publication date are written to WORM-grade storage in real time. No manual exports. No copy-paste workflows. No gaps.

Comma Compliance dashboard showing monitored site scans for adviserfirm.substack.com — daily automated scans with pages scanned, status, and policy violations tracked across three days.

What’s captured

Comma captures the full published record: newsletter issues from configured accounts, including content, timestamps, and author metadata. Each issue lands in the same archive and supervision queue as your other 40+ channels.

What this means for every team

For your compliance team

  • FINRA Rule 2210 coverage

    Substack newsletters from registered reps are retail communications. They require principal review prior to publication and must be retained for three years. Comma captures each post automatically, so the record exists from the moment it publishes.

  • Investment Advisers Act recordkeeping

    Rule 204-2 requires investment advisers to retain written communications relating to recommendations, advice, or analyses. A Substack newsletter from an RIA falls squarely into that scope. Comma captures it alongside your other advisory communications.

  • One supervision queue

    Substack posts land in the same review interface as your messaging channels. No separate workflow for monitoring publishing platforms. It's all in one place.

For your IT team

  • No device or software deployment

    Capture runs through an authenticated Substack connection. Nothing is installed on employee devices and there is no browser extension or agent to manage.

  • WORM-grade storage

    Every captured Substack post is written to the same immutable, tamper-proof WORM archive as your other channels. No Substack-specific storage to maintain.

For your employees

  • Substack works exactly as it does today

    Employees continue writing and publishing normally. Comma captures published content in the background, with no change to the Substack workflow.

  • No manual exports required

    Employees don't save, download, or forward anything. The archive is created automatically when a post publishes.

FAQ about Substack compliance archiving

Why does Substack need to be archived?
If a registered representative or investment adviser publishes Substack content that discusses securities, investments, or firm services, those posts are business communications subject to retention requirements. FINRA Rule 2210 classifies them as retail communications. The Investment Advisers Act requires retention of written communications relating to advice or recommendations. The platform doesn't change the obligation. The content does.
What exactly gets captured?
Full newsletter issues from configured accounts — including post text, publication date, and author metadata. Each issue is stored with the same metadata structure as the rest of your archive.
Do employees have to do anything differently?
No. Comma captures published content automatically. Employees write and publish to Substack as they normally would — nothing changes in their workflow.
Does Substack activity go into the same archive as our other channels?
Yes. Substack content lands in the same WORM-grade archive as your other 40+ channels, with one supervision queue for review and one place to respond to examiner requests.
Can I produce Substack records for a regulatory exam?
Yes. Captured Substack posts are searchable and exportable by date range, account, or content. When an examiner requests written communications from a specific period, Substack records are included alongside your other channels.

Your newsletters are business records.

Capture them the same way you capture everything else — automatically, into one tamper-proof archive.

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