Compliance programs for RIAs, broker-dealers, fund managers, and other registrants, from initial design through exam readiness and risk assessment. Programs built for the operating business, rather than templates that read well on the page and fail under examination.
Programs are not standardized
Compliance programs are not standardized. The right program for a five-person registered investment adviser is not the right program for a multi-strategy fund complex or a broker-dealer with retail customers under Regulation Best Interest. Off-the-shelf templates pass an initial review, then fail under examination pressure when the specifics of the business do not match the policies on the page.
The firm builds and revises compliance programs around the actual business: the products and strategies, the customer or investor base, the trading practices, the conflicts, the marketing posture, the use of placement agents and finders, the custody arrangements, and the operational seams where compliance ownership is unclear.
The deliverable
We develop a compliance program that an examiner can read in an afternoon and understand, and that the firm's staff can actually follow. Length is not the measure. Specificity to the operating business is, alongside clear accountability for each policy and a defensible record of how the policies are tested.
Annual reviews under Rule 206(4)-7 are treated as substantive exercises, not paperwork. The review documentation is the first thing an examiner asks for, and the quality of that documentation signals more about a firm's compliance posture than the policies themselves.
Examination preparation
Examination preparation follows a similar blueprint, at a different stage of the process. The questions on a typical SEC or FINRA examination are public, the document requests are predictable, and the topics of focus rotate. Preparing for an examination means knowing which of those topics fits the business, where the gaps are, and what the firm will say when an examiner asks.
Mock document requests, mock interview preparation for senior staff, and a written examination playbook are standard components. None of this is theater, examiners can tell.
Working with the firm on this matter
- 01
Assess
Risk and gap assessment against the actual business and regulator focus areas.
- 02
Design
Policies and procedures written to the operating model, not the template.
- 03
Implement
Training, supervisory structure, and documentation cadence put in place.
- 04
Test
Annual review, mock examinations, and remediation tracking.
Regulatory risk assessments
Regulatory risk assessments, the operational, conflict, and disclosure questions that drive most enforcement referrals, are usually faster than clients expect. They are also the work most likely to surface issues that can be remediated before they become matters.
The output is a short written assessment with a prioritized remediation list, not a 200-page deliverable. Issues are framed in the language the relevant regulator uses, so internal stakeholders and outside counsel work from the same vocabulary.