Every successful Registered Investment Advisor (RIA) rests on a solid foundation of documentation. It’s not just about satisfying regulators, it’s about building trust, consistency, and accountability within your practice. The right documents tell the story of your firm: how you operate, how you protect clients, and how you uphold your fiduciary duty.
But too often, new or growing RIAs underestimate how much these documents shape their compliance health and business efficiency. They’re not one-time checkboxes to file away, they’re living resources that should guide daily operations, inform decision-making, and prepare your firm for audits or unexpected challenges.
In this article, we’ll outline the five must-have documents every RIA should maintain, and why each one is essential to running a compliant, resilient, and client-focused advisory firm.
Compliance Manual – Your Firm’s Operating Blueprint
Your compliance manual is the cornerstone of your RIA’s compliance program. It’s not just a binder on a shelf, it’s the living document that defines how your firm operates, supervises, and enforces its standards. Regulators often begin every audit by reviewing your manual, because it reflects how well your firm translates policy into practice.
A well-written compliance manual should:
- Outline supervisory responsibilities and designate who oversees each area of compliance.
- Detail procedures for client onboarding, advertising review, trading, recordkeeping, and conflicts of interest.
- Address key risk areas such as personal trading, cybersecurity, and fee billing practices.
- Establish a framework for identifying, escalating, and correcting potential compliance breaches.
- Be reviewed and updated annually (or whenever your firm’s structure or operations change).
An outdated or generic compliance manual can be a red flag to examiners. Your policies should mirror your firm’s actual workflow, ensuring your documentation doesn’t just exist, but actively supports your ability to stay compliant, efficient, and audit ready.
Code of Ethics – The Standard That Guides Every Action
Your Code of Ethics sets the tone for your entire firm. It defines the values, expectations, and professional conduct that every supervised person must follow. Beyond outlining conflicts of interest, it demonstrates how your firm lives out its fiduciary duty, always acting in the best interests of clients.
A strong Code of Ethics should address:
- Personal trading policies and reporting requirements for access persons.
- Gifts and entertainment guidelines to avoid real or perceived conflicts.
- Outside business activity disclosures and approval procedures.
- Confidentiality and data protection expectations.
- Annual acknowledgment from each employee confirming their understanding.
According to the U.S. Securities and Exchange Commission (SEC, 2024, Examination Priorities, https://www.sec.gov/files/2024-exam-priorities.pdf), over 60% of RIA deficiencies identified in recent examinations were related to inadequate policies surrounding personal trading, conflicts management, and ethics oversight—all areas governed by the firm’s Code of Ethics.
That statistic underscores why this document shouldn’t be a formality. It’s a reflection of your firm’s integrity and accountability. Maintaining an up-to-date, well-implemented Code of Ethics shows regulators, and clients, that your firm doesn’t just meet the letter of the law, but the spirit of fiduciary responsibility.
Business Continuity and Disaster Recovery Plan – Prepared for the Unexpected
Every RIA, regardless of size, needs a plan for what happens when the unexpected occurs. A Business Continuity and Disaster Recovery Plan (BCP/DRP) ensures your firm can continue serving clients and protecting data even in the face of disruption, whether from technology failure, natural disaster, or cybersecurity breach.
A strong plan should include:
- Communication procedures — Clear instructions for notifying staff, clients, and regulators during an outage or emergency.
- Data backup and recovery protocols — How and where client records are stored, encrypted, and restored if systems fail.
- Key vendor and custodian contacts — Up-to-date information for business-critical partners who play a role in your recovery process.
- Alternative work arrangements — Procedures for maintaining client service if the primary office or network is unavailable.
- Annual testing and updates — A documented schedule for reviewing, testing, and revising your plan as your business or technology evolves.
Business continuity isn’t just a compliance requirement; it’s a client trust issue. When advisors can maintain stability and communication during disruption, it demonstrates professionalism and preparedness. Regulators increasingly expect firms to test these plans regularly and document results, ensuring your operations are resilient in any circumstance.
Privacy Policy and Information Security Procedures – Protecting Client Data
In today’s environment, safeguarding client information is as critical as managing their investments. Every RIA is required under Regulation S-P to maintain written policies and procedures that protect client data from unauthorized access, misuse, or loss. A well-structured privacy policy demonstrates your firm’s commitment to client trust and regulatory compliance.
A comprehensive privacy and information security program should:
- Define how client information is collected, stored, shared, and disposed of.
- Outline the safeguards your firm uses—such as encryption, secure portals, and restricted system access.
- Address vendor oversight, ensuring third-party providers meet the same data protection standards.
- Include an incident response plan detailing how the firm will respond and notify clients in the event of a breach.
- Be reviewed annually to account for evolving cyber risks, remote operations, and technology updates.
Cybersecurity has become one of the most scrutinized areas in RIA examinations, and regulators increasingly expect firms to show not only policies, but proof of implementation, like security testing, employee training logs, and vendor due diligence records.
Maintaining a thorough, regularly updated privacy and security plan helps your firm stay ahead of risk while reinforcing the trust that clients place in your care.
Form ADV & Disclosure Documents – The Face of Transparency
Your Form ADV is more than a regulatory requirement, it’s the public face of your firm. These documents outline how you operate, what you charge, the services you provide, and the conflicts you manage. Together, Form ADV Parts 1, 2A, 2B, and Part 3 (Form CRS) give regulators and clients a clear, consistent view of your business. They must accurately reflect your current practices and be updated promptly whenever material changes occur, not just at annual renewal.
Advisors often underestimate how closely regulators review these filings for consistency with actual operations. Discrepancies between your ADV and your website, marketing materials, or fee billing methods can quickly trigger scrutiny. Keeping these documents current isn’t only about compliance, it’s about transparency, professionalism, and credibility. At SimplyRIA™, we help advisors ensure their disclosures align with reality, protecting the firm’s reputation while maintaining the trust that clients and regulators expect.
Documentation That Builds Trust and Compliance Confidence
Every RIA’s success begins with a strong compliance foundation. The five core documents outlined here, the Compliance Manual, Code of Ethics, Business Continuity Plan, Privacy Policy, and Form ADV, form the backbone of your firm’s integrity and readiness. Together, they do more than satisfy regulators; they demonstrate that your firm operates with transparency, foresight, and client-first values.
At SimplyRIA™, we believe compliance shouldn’t be a burden, it should be a source of confidence. Our team helps advisors create, maintain, and evolve these essential documents so they’re more than templates, they’re tools that strengthen your firm’s credibility and efficiency.
Ready to review your firm’s documentation? Connect with SimplyRIA™ to ensure your compliance program is not only audit-ready but built for the long-term success of your advisory business.
