RIA Compliance Services for Newly Registered Investment Advisers

Launching an investment adviser firm is an exciting milestone, and getting registration is only the beginning. Once your firm is approved at the state or SEC level, the real work begins. Building a compliance program that protects your business, supports growth, and satisfies ongoing regulatory expectations and feels overwhelming.

For newly registered firms, RIA compliance services are often the difference between a smooth launch and avoidable regulatory risk. From Form ADV filings to compliance manuals and annual reviews, establishing the right foundation early helps reduce operational gaps and positions your firm for long-term success. DFP Partners supports investment advisers through each stage of this process, from initial registration through ongoing oversight and strategic compliance consulting.

What Are RIA Compliance Services for New Investment Advisers?

RIA compliance services help newly registered investment advisers meet SEC and state regulatory requirements after registration approval. These services typically include Form ADV filing support, tailored compliance manual development, code of ethics creation, testing compliance controls, regulatory exam preparation, training(s) and books and records guidance.

Step-by-Step RIA Compliance Checklist for New Firms

A strong compliance program begins with a structured registration process. While requirements may vary depending on whether you are registering with the SEC or a state regulator, the core steps generally include:

1. Establish legal entity and ownership structure
   Ensure your business formation documents, ownership records, and operating agreements are finalized.
2. Determine registration jurisdiction
   Determine the qualifications for registration with the SEC. Based on the available qualifications, confirm whether your firm must register with the SEC or applicable state securities authorities based on your size and business model.
3. Appoint a Chief Compliance Officer (CCO)
   This may be internal or outsourced depending on your firm’s structure and resources. It’s important to appoint a CCO that is qualified to hold this role based on the rules established by the SEC and applicable states.
4. Prepare and file Form ADV
   This includes Part 1, Part 2A, and, where applicable, Part 2B(s) and Part 3 (Form CRS). DFP Partners regularly supports advisers with these filings as part of its RIA compliance services.
5. Develop written compliance policies and procedures
   Your compliance framework should reflect your advisory activities, client types, custody model, and marketing practices.
6. Adopt a Code of Ethics
   This should address personal trading, reporting obligations, gifts and entertainment, and fiduciary standards.
7. Implement supervisory and recordkeeping systems
   Documentation, books and records retention, and testing protocols should be established before onboarding clients.

What SEC Compliance Requirements Apply After Registration?

New RIAs must maintain a set of written policies and procedures that are reasonably designed to detect and prevent violations of applicable regulations. The policies and procedures (often referred to as the compliance manual) should address a variety of compliance obligations ranging from Form ADV disclosures, books and records retention, annual compliance reviews, to marketing rule compliance, cybersecurity controls, and ethical business conduct.

Why the Compliance Manual Matters

A compliance manual is not simply a required document — it is the operational blueprint for how your firm manages regulatory risks and meets its compliance obligations.

For newly registered investment advisers, the compliance manual should be customized to reflect your actual business practices. This includes policies surrounding advertising review, client onboarding, fee billing, privacy protections, cybersecurity, personal securities transactions, and business continuity planning.

Generic templates often create risk because they fail to align with real operational workflows. Regulators frequently review whether written procedures match day-to-day practices. A well-developed manual helps demonstrate that your firm’s registered investment adviser compliance program is both thoughtful and actionable.

At DFP Partners, this is one of the most important early-stage deliverables we help firms build.

Form ADV Filing Requirements

Form ADV is the core registration and disclosure filing for an RIA, required under the Investment Advisers Act of 1940 (Advisers Act) and filed with either the U.S. Securities and Exchange Commission or state regulators via the Investment Adviser Registration Depository (IARD).

The Form ADV is broken into several distinct “parts”:

• Part 1 (1A/1B): Structured as a “check-the-box” and “fill-in-the-blanks” form that collects a firm’s regulatory data (business, ownership, AUM, disciplinary history). 1B is mainly for state advisers.
• Part 2A & Part 2B: Two detailed narratives that follow a prescribed outline, the “Firm Brochure” (2A) and “Brochure Supplement” (2B) are utilized to describe services, fees, conflicts, risks, and more. The Part 2A is more focused on the firm itself and is required to be filed with the Part 1 and delivered to clients. The Part 2B is focused on the firm’s personnel providing investment advice. Absent an exemption, the Part 2B would also be delivered to clients but is only required to be filed for state-registered RIAs.
• Part 3 (Form CRS): A 2-page disclosure document that follows a prescribed outline and is only deliverable to retail customers. This will also be filed with Part 1, if applicable.

All of the above ADV forms are required to be kept current, meaning any material changes should be promptly amended. At the very least, the ADV Part 1 and Part 2A are expected to be updated annually (within 90 days of fiscal year-end).

The Annual Review Process

Under Rule 206(4)-7, RIAs are required to conduct an annual review of their compliance program, which should be conducted in a manner that tests and evaluates the adequateness of the firm’s policies and procedures. Each RIA should tailor its annual review scope based on risk, which should address the specific business model and client base, among other things. At the very least, most firms will start with the following list of review areas as a foundation and build from this base:

• books and records maintenance
• personal trading and private investments
• conflicts of interest
• advisory agreements
• electronic communications
• marketing compliance
• cybersecurity, privacy and data protection
• client complaints
• fee billing methodologies
• vendor and third-party management

Regardless of the scope, the annual review should not be a checklist exercise –it should clearly outline the testing conducted, the sample sizes and the ultimate results. Lastly, the firm should document its efforts to correct any deficiencies or weaknesses uncovered during the annual review.

Ongoing Support Needs After Registration

Compliance should evolve with the business.

As your firm grows, ongoing support often includes:

• annual compliance review services
• mock regulatory exams
• marketing material review
• ADV updates and amendments
• outsourced CCO support
• compliance testing and surveillance
• employee training
• cybersecurity policy updates
• exam response preparation
• vendor risk oversight

This is where long-term RIA compliance services provide measurable value beyond initial registration support.

What Newly Registered RIAs Need Most

For firms launching their advisory practice, the most important priorities are:

• accurate registration and ADV filings
• customized compliance manual
• annual review framework
• ongoing compliance support
• proactive regulatory readiness

The strongest firms build compliance into operations from day one.

FAQs

When Should a New RIA Use a Compliance Consultant?

Many newly registered advisers choose to work with a compliance consultant when internal teams lack dedicated regulatory experience or need support with ongoing SEC requirements, annual reviews, and exam readiness. DFP Partners provides customized RIA compliance consulting, outsourced CCO support, and ongoing regulatory guidance tailored to each firm’s structure.

What are the main SEC compliance requirements for a new RIA?

Key requirements include Form ADV filings, written policies and procedures, Code of Ethics adoption, books and records retention, annual compliance reviews, and ongoing supervisory oversight.

Do newly registered RIAs need an annual review?

Yes. Under Rule 206(4)-7, advisers are expected to conduct and document an annual review of their compliance program, however, the initial review won’t likely take place until the firm has at least one year of operations under its belt.

Should a new RIA use a compliance consultant?

A compliance consultant can help ensure compliance program requirements are satisfied with confidence. New RIAs may be inexperienced with the regulatory expectations and program oversight, which comes naturally to consultants who may bring years or even decades of compliance expertise to the table.