Resources

The Working Set.

A compliance calendar. A 90-day CCO handbook. A marketing pre-flight check. Built to be used, not just downloaded.

I.

For every CCO, every year

The Compliance Calendar

139 SEC obligations, organized by quarter — the way a CCO thinks about the year.

JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
MARForm ADV Annual Update
MAYCustody Annual Audit
DECCode of Ethics Annual Cert.

II.

For your first 90 days as CCO

The 90-Day Guide

A practitioner's guide to taking ownership of a compliance program at an SEC-registered investment adviser.

I.Week Zero: Read the Public Record
WEEK ZERO
II.Days 1–30: Get Operational
DAYS 1–30
III.Days 31–60: Understand What You’ve Inherited
DAYS 31–60
IV.Days 61–90: Start Leading
DAYS 61–90
V.The Seasonality Reality Check
VI.A Few Things Nobody Tells You
VII.Your 90-Day Checklist

III.

For reviewing marketing materials

Marketing Pre-Flight

See exactly where the risk concentrates — before it reaches your CCO.

01Flagged Area

Is every performance figure in this deck net of fees — or if gross performance appears anywhere, is net performance shown immediately adjacent with equal visual prominence?

Showing gross performance without equally prominent net performance is a per se violation of Rule 206(4)-1(d)(1). A footnote does not satisfy equal prominence.

What an examiner looks for

“The adviser presented gross performance figures in its marketing materials without presenting net performance with equal prominence in the same location, in violation of the Marketing Rule’s net performance requirements.”

Rule 206(4)-1(d)(1) — Marketing Rule, Net Performance Requirement

Redan Compliance. Maintained quarterly.