RIA Compliance Manual Template
Advisers Act Rule 206(4)-7
The policy the rest of your program hangs from: who the chief compliance officer is, what authority they have, how the annual review works, and what happens when something goes wrong.
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What the rule requires
Rule 206(4)-7 requires an SEC-registered adviser to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act, to review them at least annually for adequacy and for the effectiveness of their implementation, and to designate a chief compliance officer responsible for administering them.
The rule does not list the policies a firm must have. The adopting release names the areas the Commission expects most advisers to cover, and examiners ask for the annual review and what it found.
What the policy covers
The sections of Luna's model Compliance Program policy. Your draft includes only the clauses that apply to your firm.
- 1Purpose and scope
- 2Chief Compliance Officer
- 3Annual review of the compliance program
- 4Fiduciary standards and compliance with law
- 5Violations
- 6Acknowledgment of the Manual
- 7Exceptions
- 8Records and maintenance of the program
What Luna asks you
A few of the questions that shape the draft:
- Who the CCO is, and whether they also hold another role
- Who the CCO escalates compliance matters to
- Whether outside compliance support is used, and how it is overseen
- How often compliance testing is done
How drafting works
- 01Answer questions about your firm
Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.
- 02Luna drafts the policy
Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.
- 03Review what is left
Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.
- 04Edit, approve and roll out
It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.
Read the source
Other policies
A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.