ComplyVault Blog
Regulatory developments, examination lessons and practical compliance analysis for RIAs and compliance teams.
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Your Archive Is Not Your Supervisory System
An archive can preserve communications and still leave a CCO unable to show what required attention, why a matter was cleared or escalated, and how it was ultimately resolved. Retention is essential. Supervision requires an additional evidence trail.
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Practical analysis for teams building reconstructable compliance evidence.
SEC EnforcementThe SEC’s Adit Ventures Case Shows Why Conflicts Must Be Reconstructable
The SEC’s allegations against Adit Ventures show why private-market conflicts require more than disclosure language. An RIA must be able to reconstruct each representation, transaction and approval.
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Examination ReadinessRule 206(4)-7 Requires an Effectiveness Review: Test Evidence, Not Just Policy Wording
An annual review should show whether material controls operated, identified exceptions and produced verified remediation—not merely that policies were updated.
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RIA ComplianceThe SEC Marketing Rule Requires Substantiation: Preserve the Evidence Behind Each Material Claim
Marketing approval is a moment. An RIA must still be able to reconstruct the reasonable basis behind each material claim when the SEC asks.
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Off-Channel Communications Are a Coverage Failure Before They Are a Search Problem
A complete search of an incomplete archive can produce a misleadingly clean result. CCOs need evidence of channel coverage, exceptions and remediation.
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Educational content, not legal or compliance advice.