How to Conduct an Effective RIA Annual Compliance Meeting

Let’s be honest: most RIAs treat their annual compliance meeting like a painful obligation.

Show up. Sit through a presentation. Sign the attendance sheet. Check the box.

But here’s what SEC examiners actually want to see: an engaged, substantive meeting that reinforces your firm’s culture of compliance—not a snooze-fest where everyone’s counting the minutes until it’s over.

If you’re going through the motions just to satisfy a regulatory requirement, you’re missing an opportunity. And worse, you’re setting yourself up for deficiencies during your next exam.

What Is the Annual Compliance Meeting?

The annual compliance meeting (ACM) is a required gathering of all supervised persons at your RIA to review compliance policies, procedures, and regulatory obligations.

The SEC expects investment advisors to conduct at least one compliance meeting per year as part of maintaining an effective compliance program.

But the meeting isn’t just a box to check. It’s an opportunity to:

• Reinforce your firm’s culture of compliance
• Identify areas for improvement
• Communicate updates to policies and procedures
• Document your ongoing commitment to regulatory integrity

When done right, your annual compliance meeting becomes a strategic tool for risk management and staff education.

Key Components of an Effective Annual Compliance Meeting

1. Preparation and Planning

An effective ACM starts long before anyone sits down in a conference room.

Your Chief Compliance Officer (CCO) should:

• Review the prior year’s compliance testing results and deficiency trends
• Assess new regulatory developments—SEC risk alerts, enforcement actions, and guidance
• Identify changes in firm operations that affect compliance obligations
• Develop a structured agenda with time for discussion and Q&A

Pro tip: Circulate the agenda and relevant materials at least one week in advance. When attendees come prepared, discussions are far more productive.

2. Core Topics to Cover

Each annual compliance meeting should address core compliance areas relevant to your firm:

Regulatory Overview and Updates: Discuss recent SEC or state enforcement actions and changes to rules like the Marketing Rule or Cybersecurity guidance.

Review of Your Compliance Program: Share highlights from the annual compliance review—testing outcomes, remediation steps, and areas where the firm excels or struggled.

Fiduciary Duty and Ethics: Reinforce fiduciary obligations and review your Code of Ethics, including personal trading requirements and outside business activities.

Conflicts of Interest: Identify existing or potential conflicts and discuss how to disclose and mitigate them effectively.

Marketing Rule Compliance: Review compliant advertising practices, testimonials and endorsements, and performance presentation requirements. Share recent enforcement case examples.

Cybersecurity and Data Protection: Revisit cybersecurity policies, phishing awareness, and incident response procedures. Remind employees about secure communications.

Recordkeeping and Off-Channel Communications: Reinforce WORM-compliant record retention and the prohibition of unmonitored communications like text messages or personal email. This is a hot-button issue for regulators right now.

Client Communication and Complaint Handling: Discuss best practices for client interactions and how to escalate complaints or concerns.

Focus on areas where your firm has had issues, where regulations have changed, or where enforcement activity suggests heightened risk.

3. Engagement and Participation

Here’s where most compliance meetings fail: they’re boring lectures.

Your annual compliance meeting should be interactive, not a monologue.

Encourage staff to:

• Ask questions or share challenges they’ve encountered
• Participate in case study discussions
• Identify compliance improvements or resource needs

Real-world scenarios work better than abstract policy discussions. Instead of reading the Marketing Rule aloud, walk through an actual example: “Here’s a LinkedIn post one of our advisors wanted to share. What’s wrong with it?”

This approach educates and demonstrates your firm’s commitment to open communication and accountability.

4. Documentation Requirements

If it’s not documented, it didn’t happen. At least, that’s how SEC examiners will see it.

Your CCO should maintain:

• Agenda and meeting minutes detailing topics covered, speakers, and key discussion points
• Attendance records with signatures or electronic confirmations from all supervised persons
• Training materials distributed before or during the meeting
• Follow-up items or action plans arising from the discussion

Regulators often request these materials during exams to verify that your meeting was substantive and actually conducted annually. Sloppy or missing documentation raises red flags.

5. Follow-Up and Continuous Improvement

The meeting doesn’t end when everyone logs off.

After the ACM:

• Address open issues or employee questions promptly
• Update policies and procedures as needed
• Schedule additional training sessions for deeper dives
• Incorporate feedback to make future meetings more engaging

Compliance is ongoing. Your annual meeting should kick off a year of continuous improvement, not close the book until next year.

Common Mistakes to Avoid

Treating it like a formality: Reading policies aloud for 30 minutes and collecting signatures wastes everyone’s time—and examiners will notice.

Skipping documentation: No agenda, no minutes, no attendance records = exam deficiency waiting to happen.

Ignoring firm-specific issues: Generic compliance training doesn’t cut it. Tailor your meeting to your firm’s actual risks and recent compliance challenges.

No follow-up: Identifying issues during the meeting but doing nothing about them afterward defeats the purpose.

Boring presentations: If you lose your audience in the first 10 minutes, they’re not retaining anything.

The Role of Compliance Support

Planning and executing an effective annual compliance meeting while managing all your other CCO responsibilities is a lot.

This is where outsourced compliance services can make a huge difference. An outsourced CCO can:

• Develop a comprehensive meeting agenda tailored to your firm
• Create engaging training materials and case studies
• Lead the meeting or support your internal CCO
• Handle all documentation and follow-up
• Ensure your meeting meets regulatory expectations

With professional compliance support, your annual meeting goes from “checkbox obligation” to “strategic compliance advantage.”

And if your team needs deeper training on specific topics throughout the year, RIA Compliance University offers on-demand courses covering everything from the Marketing Rule to cybersecurity best practices.

Make Your Annual Compliance Meeting Count

Your annual compliance meeting is one of the most visible indicators of your firm’s compliance culture.

Done poorly, it’s a waste of time that leaves your team uninformed and your firm vulnerable during exams.

Done well, it’s a powerful tool for education, risk mitigation, and demonstrating to regulators that you take compliance seriously.

So don’t just check the box. Plan ahead. Engage your team. Document everything. Follow up on action items.

At My RIA Lawyer, we help RIAs build compliance programs that work. From planning and leading annual compliance meetings to providing ongoing CCO support, we’re here to take the burden off your plate.

Ready to make your next annual compliance meeting your best one yet? Contact us today to learn how our outsourced compliance services can help.