NASAA Rewrote the Recordkeeping Model Rule to Match the Marketing Rule. Here's What State-Registered Advisers Should Track.
On May 4, 2026, NASAA adopted amendments to its Recordkeeping Requirements model rule (Model Rule 203(a)-2), conforming the state books-and-records template to its new advertising rule. It's a model rule, not law — so here's what actually changed, what stays the same, and what state-registered advisers should do while their own state decides whether to adopt it.