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Your First 90 Days as a Compliance Officer at an RIA
A practitioner's guide to taking ownership of a compliance program at an SEC-registered investment adviser — starting before Day 1.
Day Framework
90
Core Sections
7
Pages
12
7 Sections
Structured the way the first 90 days actually unfold.
Week Zero: Read the Public Record
Days 1–30: Get Operational
Days 31–60: Understand What You’ve Inherited
Days 61–90: Start Leading
The Seasonality Reality Check
A Few Things Nobody Tells You
Your 90-Day Checklist
Week Zero
Your firm has a public record. Read it before Day 1.
Most of what a new CCO spends the first month asking for is already published. The guide opens with the reconnaissance you can do before you accept the offer — the filings, the disclosure history, the firm’s own marketing — and how to read the ADV as a three-year diff rather than a document.
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 — and how to document your own baseline while it is still defensible.
Evidence, Not Effort
Each phase ends with something you can produce.
Days 30, 60, and 90 each close with the artifacts you should be able to hand an examiner. The firms that struggle in an examination are rarely the ones that broke a rule — they are the ones that did the work and could not show it.
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