Redan builds the record as you review marketing, vet vendors, and run training — every decision linked to its evidence, every approval to its reasoning. When the SEC letter arrives, the record is already complete.
“Strategy returned 18.4% over the trailing 12 months.”
— Fund Pitch Deck, p. 1
- Gross
- 18.4%
- Net (after fees)
- 14.7%
FINDING § 1.3(b)
Net performance must be presented with equal prominence to gross. SEC Rule 206(4)-1(d)(1).
The Platform
Three disciplines. Every decision on the record.
Every product builds a dedicated section of the Blue Folio™ — the nine-section examination record, assembled as you work.
The record the SEC actually examines.
Every marketing claim linked to evidence. CCO approval with written reasoning. Automated analysis surfaces what regulators flag, before the exam letter arrives.
VDD Platform
Third-party vendor risk classified and documented. Every due diligence decision on record, structured for examination.
Training Platform
Compliance training assigned, completed, and recorded. Every employee’s completion record on file for examination.
The Output
One document.
The record, complete.
Everything builds toward the Blue Folio: a complete, organized record ready for examination. When the examiner arrives, it’s minutes of handoff, not days of reconstruction.
BLUE FOLIO · EXAM RECORD
SHA-256: eb6b5460…3f4c
Illustrative example
Contents
- §1–3Marketing Rule Compliance127 claims · 340 evidence links
- §4Vendor Due Diligence23 assessments · signed determinations
- §5Compliance Training48 records · attestation signatures
- §6Audit TrailTimestamped · WORM · SHA-verified
The Seal
The firm is a specimen. The hash is not.
Crescent Magnolia Holdings does not exist. The bytes do: this is the exact determination record sealed above, and your browser is about to hash it in front of you.
- Sealed digest
- eb6b54609660d909fec42c75ba80ac7526ea4dedc71c31a5a6c6409cbd653f4c
- Computed in this browser
- —
SHA-256 · not yet computed
Select the record and run shasum -a 256 on it yourself. No trailing newline. That is the entire mechanism — there is nothing else to trust.
REDAN DETERMINATION RECORD firm: Crescent Magnolia Holdings (specimen) record: CMH-Q2-P4 rev 1 rule: 17 CFR 275.206(4)-1(d)(1) reviewer of record: Morgan Ellison signed: 2026-08-12T14:22:00Z determination: Approved for use provided the net-of-fees figure is presented alongside the gross figure, with equal prominence, on the same page and in the same type size. Reviewed against the firm's marketing policy and the composite the claim cites.
Why Now
The SEC isn’t looking for one finding.
It’s building a picture.
Since the2022 Marketing Rule, SEC examination has become more systematic. Examiners aren’t arriving with a single focus area. They build a pattern from what they find across marketing, vendor oversight, and training. Every undocumented decision is a data point.
The firms that answer without scrambling built the record before the letter arrived.
01
Examination is more systematic since 2022
The Marketing Rule changed how examiners approach an RIA. They are not looking for one smoking gun. They build a picture across marketing, vendor relationships, and training records.
02
Documentation gaps are the primary deficiency
CCOs fail exams not because the program was wrong, but because no documented trail connects decisions to their supporting evidence.
03
Records must pre-exist the examination
You cannot build documentation after the SEC letter arrives. Redan builds the record as you work, so on day one of an exam, your evidence chain is already complete.
The Differentiator
Faster answers. Complete records. Not a trade-off.
Compliance rigor and business velocity don’t have to trade against each other. Redan records every determination (evidence linked, reasoning on file) in the same step as the approval. Marketing gets an answer the same day. The examiner finds the record complete.
How CCOs use it →Get Started
Build your defense.
Every claim documented. Every approval reasoned. The record is already complete.