The manual, the code and the acknowledgments, on record by version.
For chief compliance officers at registered investment advisers, and the outsourced CCOs who work with them. The compliance manual and the code of ethics approved, sent to every supervised person and kept by version.
The first-day request names the manual in force during the exam period, the code of ethics and its acknowledgments, and what the last annual review left behind.
SEC Rule 206(4)-7(a)
Compliance policies and procedures
Written policies and procedures, adopted and implemented, reasonably designed to prevent violations of the Advisers Act.
Every version in effect during the exam period
Who approved each version, and when
Proof the people it covers received it
SEC Rules 206(4)-7(b) and 204-2(a)(17)(ii)
The annual review
A review at least once a year of whether the policies are adequate and carried out effectively, with any records that document it.
A review date on the manual that brings the review around each year
A re-approval or a revised version on record
The comparison showing what the review changed
SEC Rule 204A-1
Code of ethics and acknowledgments
A written code of ethics, and from every supervised person a written acknowledgment that they received it and each amendment to it.
Each person’s acknowledgment of the code
An acknowledgment for every amendment
Name, date, time and version on each record
SEC Rule 204-2
Books and records
The records the rules require, kept for the periods they set, including the policies in effect over the past five years.
Policy versions kept and retrievable
The acknowledgments behind each code version
Records documenting each review
How it helps a firm
Built for chief compliance officers who show examiners the manual, the code and the record.
The right policy to each person
Advisers, access persons and operations each get the procedures that cover them.
New hires covered from day one
Invite a new adviser with their tags and the code and manual are waiting.
No seat cost for staff
Supervised persons and other viewers are unlimited. You pay for the people who write.
Every amendment sent again
A revised code or manual is approved, then its Editor sends it out and everyone it covers is asked again.
Annual reviews on schedule
A review date puts an alert on the manual and reminds its Editor.
Proof on request
Filter the audit log by date or person and export a PDF or CSV.
Each team gets its own policies
Tag people by office, team and role. Each policy reaches only the people it covers, and new hires get theirs on day one.
Policies by team
Code of EthicsSupervised persons18 of 18 acknowledged
Personal Trading ProcedureAccess persons7 of 7 acknowledged
Business Continuity PlanAll staff18 of 18 acknowledged
Marketing ProcedureAdvisers9 of 9 acknowledged
HAHannah ArendtNew adviser · Advisers tag
Code of Ethics: receivedCode of Ethics: acknowledgedCompliance Manual: receivedCompliance Manual: acknowledged
Each team sees only the policies that cover it.
A new hire gets their team’s policies on day one.
A record for every supervised person
Show the examiner each person’s acknowledgment of the code and every amendment, with the time and the version.
“I confirm that I have received the Code of Ethics and any amendments, and agree to comply with it.”
16 Oct 2026, 09:30 UTC
Policies can go out for acknowledgment or e-sign.
Kept on record, even after they leave.
The rest of the manual
The rules set the frame, and the adopting release expects the manual to fit the firm. Each area your firm covers is a policy that needs the same control.
Personal and proprietary trading
The procedure current, with each access person’s acknowledgment of it by version.
Marketing and advertising
Review procedures versioned, so every adviser works from the same rules.
Safeguarding client assets
The procedure approved and current for everyone who handles client assets.
Privacy and information security
One current version of each policy, with its history kept and its readers on record.
Business continuity
The plan current and in the hands of everyone who has a role in it.
Handbook and acceptable use
One current version for every employee, confirmed when it changes.
Ready for whoever asks.
The first-day request names the manual as it stood, the code of ethics, its acknowledgments and the annual review. Each is an approved document with its own record.
Filter the audit log by date or person and export it as a PDF or CSV.
The manualThe version in effect on any date, and who approved it
The code of ethicsEach supervised person’s acknowledgment, by version
The annual reviewA review date, and the re-approval or revised version it produced
Outside counselInvite your lawyer to approve policies before they go out
Built around your firm
Offices and teamsTags such as Advisers, Trading or Operations send each policy only to the people it covers.
Outside counselInvite your lawyer to approve policies before they go out.
Your outsourced CCOInvite them as an Editor when they write or maintain your policies.
ExaminersGive an examiner Viewer access to the documents their tags allow.
No. They read and acknowledge as viewers, free of charge.
Acknowledgment or signature?
Both are available. Choose for each policy when you send it. E-sign is an optional add-on.
What happens when the code of ethics changes?
The revised code is approved as a new version, its Editor sends it out again, and everyone it covers is asked to acknowledge it. Earlier acknowledgments stay on record.
Does the setup differ for a state-registered adviser?
The mechanics are the same: write your policies, approve them, send them to the people they cover and keep the record. Bring the rules you answer to.
Can our outsourced CCO run this for us?
Yes. Invite them as an Editor if they write or maintain the policies.
What do we hand the examiner?
Export the document’s log, or the workspace audit log if you are an Admin, as a PDF or CSV, filtered by date or person.