What Is a Compliance Program for RIAs?
The compliance program is best understood as the whole operating system a firm uses to stay compliant: written supervisory policies (WSPs) covering day-to-day practices, a Code of Ethics governing personal conduct, a designated CCO responsible for administering and testing the program, and the annual compliance review that assesses whether it’s all actually working. Examiners evaluate these pieces together rather than in isolation — a firm can have a technically complete WSP document and still be found to have an inadequate compliance program if, for example, the CCO lacks real authority, or the annual review is superficial, or the policies don’t reflect how the firm actually operates.
The rule deliberately doesn’t prescribe a one-size-fits-all structure, since what an adequate compliance program looks like varies significantly based on firm size, business model, and the specific risks a given advisory practice faces — a solo adviser managing separately managed accounts needs a different program than a multi-office firm with custody and multiple product lines.