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  • AllyMatter for registered investment advisers

The manual, the code, and the attestations. Exam-ready.

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  • THE SURVEY MOMENT

What the examiners asks for

The request is for a record across time—not merely the document open today

  • 01

Policies and procedures in effect during the examination period

Not today’s manual: the one in force last March. Every version keeps its approval, distribution, and acknowledgment record, retrievable after the fact.
  • 02

Code of ethics attestations

Rule 204A-1 requires written acknowledgment of receipt of the code and every amendment. Each record holds the person, exact text, version, and timestamp—written, in the way examiners mean it.
  • 03

Evidence the annual review happened

The rule requires the review; examiners ask what it left behind. Review dates and the renewal flow—re-approval, certification, redistribution—put the review itself on the record.
  • THE MACHINERY

What does the work

The manual, the code, the attestations, and the record behind all three.

The manual as versioned, approved documents ->

Named sign-offs, with each document locked while under review.

Amendments re-collect acknowledgment automatically ->

A mid-year change means everyone re-attests to the amended text; word-by-word compare shows exactly what moved.

Reminders chase supervised persons on a cadence

A manual nudge handles the last stragglers; the CCO is no longer the reminder system.

Per-document exports ->

CSV and tamper-evident PDF covering versions, distribution, and attestations.

Principals who only approve pay nothing ->

Only the people who edit and manage documents need seats.

Work with an outsourced CCO or compliance consultant?

They work inside your workspace as an invited editor, every action attributed, and the firm owns the data.

  • WHERE WE STOP

The rest of the compliance stack stays yours.

Policy and attestation—not surveillance or archiving

AllyMatter is not trade surveillance, personal-trading pre-clearance, marketing review, or email archiving. RIA compliance suites do that work, and AllyMatter sits beside them, not in place of them. This is the policy and attestation layer: the manual, the code, the acknowledgments, and the proof. Nothing is scored. You get facts with names and dates; judgment stays with the CCO.

Map your policies to:

Advisers Act Rules 206(4)-7 | 204A-1 | 204-2 | state securities regulations

Facts: person · exact text · version · timestamp

Judgment: stays with the CCO
  • FAQS

Frequently asked questions

We are state-registered, not SEC. Does this still fit?

The mechanics are identical; bring your state's rulebook and map your policies to it. -> /standards/custom

Every change goes back through approval and re-collects written acknowledgment against the amended text. Nobody's January signature gets read as agreement to July's code.

Per-document exports, CSV or tamper-evident PDF: versions, approvals, distribution, and every attestation. You produce exactly what the request list asked for, without a week of assembly.

Adopted and implemented, with the record to match

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