Stepping Into the Role: Building or Rebuilding a Compliance Program as a New CCO
- Coulter Strategic Services
- Dec 2, 2025
- 6 min read
Stepping into the Chief Compliance Officer role for a registered investment adviser can feel overwhelming, whether you are a dedicated compliance professional or an owner or principal who has taken on the CCO title. This is true even if day-to-day tasks are delegated to support staff or an outside compliance consultant, because responsibility for the program ultimately remains with the firm and its CCO. The key is to pause, assess, and rebuild on a sound foundation before making changes. A new CCO’s first 90 days should balance learning the firm’s operations with confirming that the compliance framework meets regulatory expectations and working toward enhancing and strengthening the program through clear communication and structured tasks, recognizing that compliance is a living program that needs regular attention and care much like a tended garden.
Start With What Exists
Before drafting new policies or procedures, start by reviewing what the firm already has in place. Gather all existing compliance documents, including but not limited to the Compliance Manual, Code of Ethics, Form ADV Parts 1 and 2, the CRS, client agreements, marketing materials, recent testing records, and prior annual review results. Confirm when each item was last updated and whether it reflects the firm’s current structure, business lines, technology, and supervision model. Note inconsistencies, outdated procedures, or gaps between stated policies and actual practices.
It is equally important to involve the firm’s business partners and key staff during this assessment so the CCO or compliance team can understand how the firm operates day to day. Participate in internal meetings, even if only in listening mode initially, to observe how decisions are made and where compliance fits into the workflow. Sit with staff to see how they carry out their responsibilities in real time and how systems are actually used. This reveals informal processes, workarounds, and operational habits that may not be captured in written procedures. These interactions also help you gauge how well employees understand relevant compliance requirements and identify knowledge gaps that should be addressed through future training or procedural updates.
A simple but effective step is to compare the manual to actual operations. Ask whether it accurately describes what occurs in practice. For example, if the manual states that personal trading reports are reviewed weekly, confirm that this review is happening as written.
The process offers far more insight into the firm’s culture, resources, and overall readiness for regulatory expectations than any checklist alone could. Taking time to observe how the firm actually functions, how staff carry out their responsibilities, and how written procedures align with daily practices provides the context needed to build or refine a compliance program that truly fits the business.
Know the Core Rules
Every CCO should ground the firm’s compliance program in the Investment Advisers Act of 1940 and its key implementing rules. At a minimum, the compliance team should understand and be able to map policies, procedures, and testing to:
Section 206 of the Advisers Act, which establishes the adviser’s fiduciary duty and anti-fraud obligations.
Rule 206(4)-7, which requires written policies and procedures, an annual review of their adequacy and effectiveness, and the designation of a Chief Compliance Officer.
Rule 204-2, the Books and Records Rule, which outlines the records advisers must create and retain.
Rule 204A-1, the Code of Ethics Rule, including access person reporting and personal securities transaction monitoring.
Rule 206(4)-1, the Marketing Rule, governing advertising, testimonials and endorsements, performance information, and related recordkeeping.
Rule 206(4)-2, the Custody Rule, addressing the holding, accounting, and reporting of client assets, including surprise examinations when custody exists.
Rule 206(4)-5, the Pay-to-Play Rule, which restricts political contributions and solicitation activity involving government entities.
Rule 206(4)-6, the Proxy Voting Rule, which applies when the adviser votes client securities.
Rule 204-1 and related Form ADV filing requirements, including annual amendments and prompt updates for material changes.
These Advisers Act provisions form the structural baseline for firm compliance program. A new CCO should be able to identify where each requirement is addressed in the firm’s Compliance Manual and related procedures and how compliance with each rule is tested and documented.
This is not an exclusive list. Depending on the adviser’s business model and client base, other regulatory frameworks also apply, such as privacy and safeguarding requirements under Regulation S-P, identity theft obligations under Regulation S-ID, state securities rules, and ERISA considerations when working with retirement investors. Firms with specialized activities may have additional requirements.
For a complete and current view of all applicable rules, CCOs should review the SEC’s official website.
Engage With the Firm
Effective compliance programs are built on communication and collaboration. Early in your tenure, take time to build relationships with leadership and key staff. These conversations help you understand how decisions are made, how information flows through the organization, and where compliance input is expected. Establishing open communication channels also encourages staff to raise questions early, which reduces risk and promotes a culture where compliance is viewed as a partner in the business rather than an audit function.
Engaging with the team at this stage sets expectations for how compliance will support the firm, reinforces the shared responsibility for regulatory obligations, and helps the CCO identify where additional guidance, training, or process clarification may be needed.
Conduct an Initial Program Review
At a minimum, the first 60 days should be used to complete a focused assessment of the compliance program. Approach this period as an informal mini-annual review to identify the most significant risks or gaps. Concentrate on areas that typically carry the most regulatory scrutiny, such as trading oversight, marketing reviews, billing practices, and vendor due diligence. Look for issues that require immediate attention, identify where procedures need clarification, and note any resource constraints that may affect implementation.
If the firm works with an external compliance consultant, use this time to clarify expectations and ask targeted questions. An experienced consultant can help you confirm whether the program addresses common exam issues, identify disclosure inconsistencies, and provide guidance on how to structure your first full annual review.
Invest in Professional Resources
Even experienced professionals benefit from connection to the broader compliance community. Consider joining the National Society of Compliance Professionals (NSCP) or similar organizations that provide training, networking, and interpretive guidance. Membership offers access to roundtables and regional discussion groups where CCOs share current exam trends and practical solutions in a setting that allows participants to share insights without attribution outside the group. These discussions help you benchmark your program against industry standards and learn how others implement new rules.
Staying active in local compliance roundtables and national organizations also helps you anticipate rule changes, interpret new guidance, and build a professional support network that will be invaluable during exams or transitions.
Develop a Roadmap
After reviewing documents, engaging the team, and understanding the regulatory framework, outline a 12-month compliance roadmap. This plan should identify:
• Policy and disclosure updates needed immediately.
• Areas that require testing or remediation.
• Training priorities for staff.
• Deadlines for the next annual review and Form ADV amendment.
• Any resource needs, dependencies, or system improvements required to support the program.
• A timeline that distinguishes between high-risk items that must be addressed promptly and longer-term enhancements.
A written plan demonstrates control and accountability. Share it with firm leadership so compliance priorities are visible and properly resourced. Reviewing and updating the roadmap throughout the year keeps the program aligned with operational changes, regulatory updates, and exam priorities.
A new CCO’s success depends less on rewriting policies and more on understanding how the firm operates and how its people make decisions. By taking time to evaluate, engage, and plan deliberately, compliance becomes not just a regulatory requirement but an integrated part of how the firm does business.
If you found this article helpful, please like and share it to help advisory professionals strengthen their compliance programs.
Coulter Strategic Services provides customized compliance and regulatory consulting designed to meet the specific needs of each investment advisory firm. Services are tailored to the firm’s structure, business model, and regulatory obligations to help maintain an effective and sustainable compliance program aligned with current expectations. Contact us today to discuss your firm’s compliance program needs. Learn more at https://www.coulterstrategicservices.com/
All information provided is for educational purposes and should not be construed as specific advice. The information does not reflect the view of any regulatory body, State or Federal Agency or Association. All efforts have been made to report true and accurate information. However, the information could become materially inaccurate without warning. Not all information from third-party sources can be thoroughly vetted.
Coulter Strategic Services and its staff do NOT provide legal opinions or legal recommendations. Nothing in this material shall be considered as legal advice or opinion.
Excellent article!