Programs

A Compliance Calendar for a Small RIA

Most compliance failures are not decisions. They are deadlines nobody was watching.

Most compliance failures at small advisers are not bad decisions. They are deadlines that slipped because no one owned them. A compliance calendar is the unglamorous tool that turns a scatter of recurring obligations into scheduled, assigned tasks, and it prevents more findings than almost anything else.

What belongs on it

A small adviser's calendar typically includes the annual updating amendment to Form ADV, delivery of updated disclosures and Form CRS, the annual review of the compliance program, code-of-ethics and personal-trading reviews, the annual privacy notice, and any state renewals and filings. Add periodic marketing reviews, cybersecurity checks, and books-and-records housekeeping, and the year fills quickly.

Why the calendar wins

The obligations are not individually hard; they are just numerous and time-bound, and a firm without a system relies on memory, which fails. A living calendar with owners and due dates converts compliance from a scramble into a routine. Examiners can often tell within minutes whether a firm runs on a calendar or on luck.

Keeping it alive

The calendar itself needs an owner, usually the CCO, and a habit of reviewing it. It should be updated when rules change or the business does. A calendar built once and ignored is no better than none.

Schedule the obligations, or the obligations schedule your findings.

Greenridge L&C Advisors is a compliance consultancy, not a law firm. This is general information, not legal advice.

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