My RIA Lawyer

05/29/2026

Your CCO probably isn't the problem.
The structure around them is.

Most firms have one person carrying compliance, with a few outsourced consultants and a tech stack layered on top. On paper it looks covered. In practice, no one is holding it together — and the gaps don't surface until an exam or an issue forces them to.

Compliance should not depend on one person's bandwidth, memory, or calendar.

That's not a CCO problem. That's a governance problem.

05/28/2026

Three things most $1B+ RIAs have in place, and what each one actually does:
🔵 A compliance consultant runs your annual review and tells you what they found.
🔵A law firm responds when something goes wrong and tells you what to do.
🔵An integrated compliance partner sits between your CCO, your COO, and your executive team — and makes sure the program is operationally sound before either of the above become necessary.

Most firms we engage with already have the first two.

What they're missing is the third — the structural layer that makes the first two rarely needed.

05/27/2026

Most RIAs think they're compliant. They're not.

On paper, everything checks out — a CCO is named, processes exist, annual reviews are done. But the SEC isn't grading the paperwork. They're testing whether the program actually works.

For most firms, it doesn't. One person carrying the function. Disjointed vendors. Reactive processes stitched together over time.

The problem isn't that the program is missing pieces. It's that the structure was never built to hold under examination.

You usually find out which one you have at the worst possible moment.

05/22/2026

Firms don't come to us looking for outsourced compliance services.

They come to us because something feels off. They don't trust their current structure. They've outgrown it. Or they're about to be tested — and they realize the answer isn't more support.

It's a different structure.

That's the conversation worth having before regulators force it.

05/20/2026

One person with a title is not a compliance department.

Most outsourced CCO arrangements run through a single individual — which means limited bandwidth, inconsistent oversight, and zero redundancy. When your entire compliance function depends on one person's calendar, that is a structure problem, not a staffing problem.

Growth-stage RIAs need a department behind the title.

05/19/2026

Thanks so much LevelUp Local & Studio Von YEG

Brand photography rule #1: don't tell people to "act natural." Just let them BE.

Yes, direction & coaching are important, but also allowing space for your clients to just BE them. Get them to check their emails, scroll social media, answer a text, you can have the scene setup while also allowing space for natural & authentic presence.

Have a great Friday & long weekend!!

My RIA Lawyer LevelUp Local

05/19/2026

I want to share something a client said last month, because it names a problem I see constantly — but rarely hear articulated this cleanly.

https://www.linkedin.com/pulse/paul-winkler-proof-point-integrated-vs-reactive-compliance-ruake

05/15/2026

➡https://www.myrialawyer.com/compliance-risk-review/