A newly registered firm does not get a grace period on compliance. From the day registration is effective, it is expected to have a real, working compliance program, and the most common early mistake is downloading a template, filing it, and operating a business it does not describe.
A functioning program starts with written policies and procedures tailored to the firm's actual business, a designated and empowered chief compliance officer, a code of ethics with personal-trading oversight, and the recordkeeping to prove it all. Add the disclosure documents, Form ADV and Form CRS, a marketing-review process, a privacy and data-security program, and a compliance calendar to run the recurring obligations.
The rule requires policies reasonably designed for the firm's specific conflicts and risks, so a generic template is a liability the moment an examiner compares it to how the firm actually operates. The program should be built from the firm's real practices outward, describing what it truly does and controlling its real risks, not what a sample document assumes.
The rules also require an annual review of the program's effectiveness, so a new firm should build with that review in mind: policies specific enough to test, records complete enough to demonstrate, and an owner accountable for the whole. A program built to be examined is a program that survives being examined.
Build the real firm's program, not the template's.
Greenridge L&C Advisors is a compliance consultancy, not a law firm. This is general information, not legal advice.