Rule 206(4)-7 Every element, on every program — verified, not assumed

The most rigorous compliance program an RIA can have.

RIA Compliance Program Engine delivers a done-for-you, exam-ready compliance program — Form ADV filed on time, a documented annual review, cleared marketing, and an audit-grade books-and-records file — produced by an internal AI engine and signed off by a qualified compliance professional. The adviser experiences a trusted compliance partner, not a software tool they have to operate.

Every element of Rule 206(4)-7 and the Marketing RuleForm ADV annual amendment within 90 days of FYEDocumented annual review with audit trailMarketing pre-clearance under the new Marketing Rule5-business-day SLA for standard filings
Why programs fail

A single missing element can trigger a deficiency letter.

Every SEC- and state-registered investment adviser must, by law, run a written compliance program, file an annual Form ADV amendment, conduct a documented annual review under Rule 206(4)-7, pre-clear marketing under the Marketing Rule, and keep an exam-ready books-and-records file. Yet most small and mid-size firms run this on spreadsheets, a part-time CCO who is also the founder or COO, and one overworked outside consultant.

The penalty for getting it wrong is a deficiency letter, an enforcement sweep, personal liability for the CCO, and six-figure fines — the SEC collected over $600M in off-channel-communications penalties in FY2024 alone and continues to run Marketing-Rule sweeps.

RIA Compliance Program Engine exists to close that gap with a single, exhaustive standard applied identically to every firm.

$600M+
in SEC off-channel-communications penalties in FY2024
The benchmark

Measured against the letter of the Advisers Act — rule by rule.

We do not summarize the law and hope. Every program is scored against a versioned rule pack tied to the exact text of the Investment Advisers Act of 1940 and SEC rules. These are the provisions each program is held to.

Rule 206(4)-7

Annual compliance review

A documented annual review of the firm's compliance policies and procedures, with a written report and evidence of testing — all present, or the program does not release.

Form ADV (Part 1 & 2A)

Annual amendment filing

Form ADV annual amendment filed within 90 days of fiscal year-end, reconciled against the firm's actual practices and disclosures.

Rule 206(4)-1 (Marketing Rule)

Marketing pre-clearance

Every advertisement is reviewed for substantiation, fair presentation, and required disclosures before use, with a documented clearance log.

Rule 204-2 (Books & Records)

Audit-grade recordkeeping

All required books and records maintained, organized, and ready for exam production within 24 hours.

Rule 206(4)-7 (Policies & Procedures)

Written compliance manual

A current, firm-specific compliance manual addressing all applicable rules, with annual attestation and training records.

SEC Exam Priorities

Exam-ready posture

A pre-exam readiness file including prior deficiency responses, sample trade documentation, and a mock-exam report.

How a program is built

Intake to specialist release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A qualified compliance professional signs every release. That order is never reversed.

01

Compliance Gap Scan

Upload your current ADV, compliance manual, and recent exam history. We return a free completeness read: which regulatory elements you already have, and which are missing.

02

Evidence & data collection

As your authorized clerical agent, we collect your firm's actual practices, marketing materials, trade data, and communications records to build a complete compliance baseline.

03

Grounded drafting

All compliance documents are drafted from your validated data and the rule pack into field-locked templates — no legal opinions, no invented facts.

04

Deterministic completeness gates

ADV fields reconcile to your practices; the annual review checklist is resolved; marketing substantiation is verified; books-and-records inventory is complete. Any failure blocks release.

05

Specialist release

A qualified compliance professional reviews the exception queue and signs the release. High-risk or novel matters route to partner securities counsel first.

06

Delivery

You receive the program: filed ADV, compliance manual, annual review report, marketing clearance log, books-and-records file, and exam-ready binder — ready for your CCO to own.

The bar we hold

Rigor you can measure.

100%
Specialist-released
No program ships without a human signature.
5 days
Standard SLA
From complete intake to released program for standard filings.
<1%
Critical-defect target
Tracked against a gold-standard program library.
4
Regulatory domains
ADV · Annual Review · Marketing · Books & Records, every applicable rule.
Why RIA Compliance Program Engine

Built to be the most thorough option an RIA has.

Documentation-complete, by design

The deliverable is completeness itself — every regulatory element and record accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A drafting error cannot slip past a regulatory requirement.

In its lane, on purpose

We prepare documentation and run searches as your clerical agent. We never give legal advice, and we partner with securities counsel for legal opinions.

Engagement

Annual program retainer + per-unit fees. No hourly billing, ever.

Simple, predictable, and aligned with a compliance standard — not a cut of any recovery.

  • A free Compliance Gap Scan before you commit — see exactly what is missing.
  • One annual retainer per firm, plus per-unit fees for filings, ad clearances, and reviews.
  • Optional fixed-fee attorney review for complex or high-risk matters.
  • Optional Exam-Ready Add-on for mock exams and pre-exam preparation.
FAQ

Questions, answered precisely.

Is RIA Compliance Program Engine a law firm?
No. RIA Compliance Program Engine, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-risk matters.
Do you file Form ADV directly with the SEC?
We prepare the Form ADV amendment and all supporting documentation for your review and approval. You or your authorized signatory files it through IARD. We never file without your explicit authorization.
What makes a program 'complete'?
Completeness is defined by the Advisers Act and SEC rules: the annual review documented, ADV reconciled, marketing cleared, books-and-records in order, and policies current. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is five business days from complete intake to a specialist-released program. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
An annual retainer plus per-unit fees for specific deliverables (e.g., each ad clearance, each filing). No hourly billing and no contingency.

See what's missing before it costs you a deficiency letter.

Start with a free Compliance Gap Scan. Send your current ADV and compliance manual and we'll return a completeness read against every applicable rule.

Documentation-completeness service · not legal advice · your CCO retains full responsibility.