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.
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.
III.
For reviewing marketing materials
Marketing Pre-Flight
See exactly where the risk concentrates — before it reaches your CCO.
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.