You Just Registered Your RIA. Here's What the SEC Expects on Day One.
You've made it through the Form ADV gauntlet, picked a custodian, and you're officially in business. Before you start celebrating, there's something you need to know.
You're already on the SEC's radar.
The Division of Examinations' FY2026 published priorities explicitly state that newly registered advisers are a target for examination. Not "might get around to it." Priority. They want to see that you built a compliance program from day one, not that you're figuring it out after you get the exam notification letter.
And you're not alone. In 2023, 1,114 new advisers registered with the SEC. Nearly 94% of them had less than a billion dollars in assets under management. These are small firms, the median SEC-registered adviser has 8 employees and a single office. Most of them don't have a dedicated compliance person. The founder is the CCO, the portfolio manager, and the rainmaker all at once.
That's the reality the SEC knows when they show up. And here's what they expect to find.
A written compliance program, not a downloaded template
Rule 206(4)-7 under the Investment Advisers Act requires every registered adviser to adopt and implement written policies and procedures reasonably designed to prevent violations of the federal securities laws. That's the legal language. In practice, it means you need a compliance manual that describes what your firm actually does and how you prevent the specific risks that apply to your business.
The trap most new advisers fall into is downloading a compliance manual template from the internet, swapping in their firm name, and filing it away. That template probably includes policies for activities you don't engage in and omits policies for things you do every day. When an examiner reads your manual, they build their examination checklist from it. Every policy you've committed to in writing becomes a standard you'll be measured against. If your manual says you pre-clear personal trades and you don't have pre-clearance logs, that's a deficiency, not because you did anything wrong with your trading, but because you said you had a process and you didn't follow it.
A compliance manual for a solo or small RIA should accurately describe your actual business activities, include specific procedures (not just policies), and map to a calendar so every recurring obligation has a date attached to it.
A Code of Ethics with teeth
Rule 204A-1 requires a separate Code of Ethics. This isn't the same document as your compliance manual. It covers personal trading policies, reporting requirements for access persons, and a process for reporting violations.
Even if you're a solo adviser, you are an access person. You still need to document your personal securities holdings (annually) and transactions (quarterly). You still need a pre-clearance process, even if you're pre-clearing your own trades. The documentation is the point, examiners want to see that a process exists and that you followed it consistently.
Form ADV Part 2A that matches your practice
Your firm brochure must be delivered to clients before or at the time they sign an advisory agreement. It needs to accurately disclose your fees, conflicts of interest, investment strategies, and disciplinary history. This is the document examiners cross-reference against your actual operations. If Part 2A says you charge 1% and your agreements say 1.25%, that's a disclosure problem. If it says you invest primarily in equities and you're putting clients in alternatives, that's a mismatch.
Part 2A is also where you describe your advisory services. If you offer financial planning, and 44% of SEC-registered advisers do, your brochure needs to describe the scope, the fees, and any limitations on that service. If you added financial planning this year but haven't updated Part 2A, you have a disclosure gap.
Form CRS for retail clients
If you serve retail investors, Form CRS (Part 3 of Form ADV) is required. It's a two-page relationship summary covering services, fees, conflicts, and disciplinary history, written in plain English. The SEC has enforced formatting and content requirements strictly since the Marketing Rule took effect, and CRS deficiencies have become a common examination finding.
Books and records from day one
Rule 204-2 specifies what records you must maintain and for how long. At minimum: client agreements, correspondence, trading records, fee calculations, your compliance manual, and Code of Ethics acknowledgments. Know where each record lives, your CRM, your custodian platform, your email archive, and document that mapping. An examiner will ask "where do you keep your client correspondence?" and expect a specific answer, not a shrug.
The bottom line
The SEC expects new advisers to have a functioning compliance program from the day they register. Not from the day they hit $500 million. Not from the day they get their first exam notification. From day one.
Over 92% of advisory firms have 100 or fewer employees. Most are small businesses run by people who got into this industry to manage money and serve clients, not to build regulatory infrastructure. But the regulatory infrastructure is what keeps the doors open.
If you're newly registered and your compliance program is a downloaded template you haven't read, a Code of Ethics you haven't signed, and a vague plan to "figure it out later", later is already here. The SEC said so in writing.