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Your First 90 Days as CCO

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

Day Framework

90

Core Sections

9

Pages

12

9 Sections

Structured the way the first 90 days actually unfold.

Before Day 1

Days 1–30: Get Operational

Stakeholder Mapping

The Inherited Landscape

Exam Readiness

Days 61–90: Start Leading

Budget & Authority

Seasonality Reality Check

Your 90-Day Checklist

The Inherited Landscape

Know what you own before you own it.

The most dangerous compliance risks are the ones you didn’t create. The guide walks through how to surface the predecessor’s record — what was decided, documented, and left unresolved.

ADV & Exam Readiness

Your first ADV and your first exam are closer than they appear.

Your first ADV filing and your first regulatory exam will both happen faster than they appear from the start date. The guide maps each obligation to the 90-day window where it becomes urgent.

Building the Program

The first 90 days either build the program or they don’t.

Compliance culture is built in the first 90 days or it isn’t built at all. The guide covers the conversations, documentation practices, and recurring rhythms that define a credible program.

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