Agent pre-evaluates every manual section against firm activity, rule changes, and prior-year findings. CCO and counsel review judgement calls, not data assembly. The $15K consulting line item goes away.

Under Rule 206(4)-7 every SEC-registered RIA has to run a written annual compliance program review confirming the program is functional, appropriate for the business, and consistent with current rules. The mechanics are blunt: walk every page of the compliance manual and the code of ethics, ask whether the firm actually does what the document says, document the answer, and update either the policy or the practice so they match. The penalty for getting it wrong runs in both directions. If the manual claims a practice the firm does not perform, the SEC writes a finding. If the firm performs a practice that is not in the manual, the SEC writes a finding.

The industry-standard delivery is a consulting engagement. Outside consultants charge roughly $15,000 just for the manual update and the matching incident response plan, walk through every section with the CCO over two to three days, build a redline review document, and hand back a new manual. The work is real and the expertise is genuine. But the underlying data (the firm''s attestations, trade reviews, training records, marketing approvals, complaint files, vendor due diligence) already lives in the firm''s systems. The consultant is paid in part to read it back to the CCO.

The firm that runs this annually with the evidence already assembled needs the consultant for judgement, not for data collection.