Pointpath Docs

Fund website regulatory requirements

Failover platform requirements

The failover site answers at the same hostnames and paths as the primary, hosts the documents itself, and shares nothing that could take both down at once.

Addresses and access

GEN-01 Required

Every address printed in a fund document (summary prospectus cover URL, shareholder report URL) resolves on failover at the identical path and lands directly on the documents. No redirect to a home page or a generic "site unavailable" page.

Basis
ADI 2025-15; Rule 498(b)(2)
GEN-02 Required

Failover hosts the regulatory documents itself. Linking to EDGAR does not satisfy Rule 30e-1, which bars using the SEC's filing system as the specified address.

GEN-03 Required

Public and free: no login, cookie wall, email gate or bot challenge in front of required content. Exempt regulatory paths from Cloudflare challenge and "Under Attack" modes on both origins.

Basis
Rules 498(e)(1) and 30e-1(b)(2), "publicly accessible, free of charge"
GEN-04 Required

Same hostname, same TLS: the failover origin carries a valid certificate for every fund hostname (wildcard or Cloudflare origin certificate), so a switch never produces a browser security error.

Basis
Follows from GEN-01 and GEN-03

Independence and switchover

GEN-05 Required

Failover runs on a different host and provider or region than the primary, with no shared cPanel server, database or CodeIgniter runtime. Prefer a static build (pre-rendered HTML, PDFs and JSON) so it has no app-tier dependency.

Basis
Reasonable procedures, Rule 498(e)(4)(i)
GEN-06 Required

Cloudflare health checks fail traffic to the failover origin automatically. Target recovery time of 5 minutes or less; the client sets the final number. Pointpath and the client can also switch manually.

Basis
Prompt action, Rule 498(e)(4)(ii)

Keeping the two origins identical

GEN-07 Required

Dual publish: daily and periodic data is written to primary and failover by the same job at the same time, not copied over after the primary goes down. A failed write to either side alerts.

Basis
The ETF pre-open deadline has no safe harbor
GEN-08 Required

A superseded prospectus, SAI or report is removed from failover the same moment it is replaced on the primary. A stale document on failover is a live violation.

Basis
Rule 498(e)(1), "current"
GEN-09 Required

Documents are human-readable, convenient to read online and to print, and downloadable to keep free of charge. If failover serves PDFs only, those PDFs must keep hyperlinked tables of contents and the summary prospectus links to the statutory prospectus and SAI.

Basis
Rules 498(e)(2)–(3) and (f)(3); 30e-1(b)(2)(iv)–(v)
GEN-10 Required

ETF and money market fund data must be as easy to find on failover as on the primary: on the fund page, not behind a buried link.

Basis
Rules 6c-11(c)(1) and 2a-7(h)(10), "prominently"

Monitoring and evidence

GEN-11 Required

A daily synthetic check hits the failover origin directly (bypassing DNS) and confirms each required item is present and carries the expected as-of date.

Basis
Reasonable procedures
GEN-12 Required

Timestamped record of every post on both origins and every failover activation and recovery, kept at least as long as the client's records policy. It supports the safe harbor and proves day-8 premium/discount postings.

Basis
Rules 498(e)(4), 30e-1(b)(2)(vi), 6c-11(c)(1)(vi)
GEN-13 Recommended

Failover is tested on a schedule (quarterly suggested), with the client's compliance team signing off on this checklist.

Basis
Reasonable procedures
GEN-14 Conditional

Anything beyond required disclosures shown on failover (performance, commentary, fact sheets) must be the same compliance-approved version live on the primary. Simplest approach: failover shows regulatory content plus approved fund pages only.

Basis
FINRA Rule 2210 approval and recordkeeping