Compliance that runs itself. Almost.
Nomos is an outsourced chief compliance officer and compliance consulting firm for solo, small, and midsize registered investment advisers nationwide. We build the program, run the filing calendar, and hold the documentation — so the deadline passes, the exam closes, and you go back to advising.
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The compliance rule applies to everyone. Written policies, a designated CCO, and a documented annual review — regardless of firm size or AUM.
The calendar does not negotiate. The Form ADV annual updating amendment is due within 90 days of fiscal year end. Everything else has its own date.
Newly registered firms are an exam priority. The SEC's Division of Examinations has flagged recently registered and never-examined advisers for 2026.
Six questions. Then watch your register build itself.
Real rules, real cadences, real dates counted from today. This is the ledger we would carry for you — and a version of the one an examiner will ask you to produce.
Illustrative and not exhaustive, and not legal or compliance advice. Dated items assume a December 31 fiscal year end where one applies and do not adjust for weekends, holidays, or state-by-state variation. Your real obligations turn on facts six questions cannot capture — which is roughly the point.
That list is what we take on. Every row, every date, every year.
Hand it to usTwelve months, plotted.
The recurring dates a December-31 adviser carries, drawn against today. Every one of these is a morning you do not have to think about.
What does an outsourced CCO actually do?
An outsourced CCO carries the compliance program a registered investment adviser is required to maintain: the written policies, the documented annual review, the filings, the testing, and the records. Engagements are typically full outsourced CCO relationships, but each piece can stand alone.
Outsourced Chief Compliance Officer
We serve as your dedicated compliance function: maintaining the program, running the annual review, and owning the documentation trail. You keep the designation; we do the work behind it.
Registration and ongoing filings
Initial SEC or state registration, Parts 1, 2A, 2B and Form CRS, annual updating amendments, other-than-annual amendments, IARD administration, and state notice filings.
Policies, procedures, code of ethics
A manual written for how your firm actually operates — not a template with someone else's business model in it. Personal trading, gifts, political contributions, privacy, continuity.
Review and ongoing testing
The documented annual review the rule requires, plus forward testing: fee and billing accuracy, best execution, advertising substantiation, electronic communications, personal trading surveillance.
Exam readiness and regulator support
We run the exam before the regulator does — request list, interviews, findings, remediation plan with dates. When a real exam arrives, we assemble the production and draft the response with you.
Marketing Rule review
Website, decks, social, testimonials and endorsements, third-party ratings, and performance presentation — reviewed against the Marketing Rule, with the substantiation file built and kept.
Privacy, cybersecurity, vendors
Written information security and incident response programs, annual privacy notices, vendor due diligence, and the governance documentation examiners now ask for by name.
Books and records
Retention schedules, electronic communications capture and archiving, advertising files, and a record set that can be produced on request instead of reconstructed under deadline.
Too small for a full-time CCO. Too regulated to go without one.
Registered investment advisers nationwide — state and SEC registered — from a first-year solo practice to an established multi-adviser firm.
The one-person firm
You are the adviser and the CCO on paper. You need the program to exist, be current, and be defensible — without becoming a second job.
- Initial or transition registration
- Manual built around your actual practice
- A filing calendar we run, not one we send you
- Someone to call before you do the thing
Two to fifteen people
Enough staff for personal trading, marketing, and supervision to become real compliance surfaces — not enough to hire someone to watch them.
- Full outsourced CCO engagement
- Code of ethics administration
- Advertising and Marketing Rule review
- Annual review, testing, mock exam
Growing and examined
Multiple offices, a growing book, maybe an internal compliance associate. You need depth and a second set of eyes, not a starter kit.
- CCO support or co-sourced model
- Build-out for new services or products
- Exam management and remediation
- M&A and adviser onboarding diligence
How does an outsourced CCO engagement work?
The first ninety days are the heavy lift. After that, compliance becomes a cadence rather than an event.
Assessment
We review your manual, filings, records, marketing and any prior exam history, and give you a written gap assessment.
Build
We rewrite or build the program to fit your firm, correct filing and disclosure issues, and put the record-keeping in place.
Handoff
Every recurring obligation goes onto a dated calendar we own. One view of what is due, done, and needs your signature.
Run
Quarterly testing, marketing review, personal trading surveillance, filings when due, and a standing line for everything between.
Review
The documented annual review, a mock examination, and a written report you can hand to a regulator, custodian or acquirer.
What is actually in front of advisers right now.
A sample of what we are tracking on behalf of clients as of August 2026. Tracking these so you do not have to is most of what the job is.
Regulation S-P amendments
Smaller advisers were required to comply with the 2024 amendments — including a written incident response program and customer notification obligations — by June 3, 2026. Reg S-P and S-ID are named 2026 exam focus areas.
SEC 2026 PrioritiesForm ADV annual amendment
For a December 31 fiscal year end the annual updating amendment was due March 31, 2026. Parts 2A and 2B need to be accurate at the same time, and IARD fees deposited ahead of submission.
Form ADV General InstructionsFiduciary duty and the Marketing Rule
Examiners are looking at duty of care and loyalty around complex, alternative and higher-cost products and advice to older investors — plus substantiation of marketing claims, hypothetical performance, testimonials and third-party ratings.
SEC 2026 PrioritiesThe investment adviser AML rule
FinCEN finalized a two-year postponement of the AML/CFT program and SAR filing requirements for registered and exempt reporting advisers while it revisits scope. The pause is not a cancellation — the build should start well before the date.
FinCEN final ruleUse of AI and automated tools
Advisers using automated or AI-driven technology are being examined on whether representations match reality, whether use is consistent with disclosures and client profiles, and whether there are actual controls around it.
SEC 2026 PrioritiesCustody and standards of conduct
The custody rule remains a core exam area — including inadvertent custody through fee deduction arrangements, standing letters of authorization, and access to client credentials.
SEC 2026 PrioritiesStraight answers.
Can you actually be our chief compliance officer?
An adviser has to designate a supervised person as its CCO, and that designation stays with your firm. In practice an outsourced arrangement can be structured either way: we can serve in the role under an arrangement that makes us a supervised person, or your named CCO keeps the title while we perform the underlying work and carry the program.
Which structure fits depends on your firm, your regulator, and your insurance. We will walk through the trade-offs on the first call rather than assume one.
What does it cost?
Engagements are flat fee — an annual or monthly retainer for ongoing outsourced CCO work, and a fixed project fee for one-time work like a registration or a mock exam. Price depends on firm size, number of supervised persons, services offered, and the state your program is in when we start.
You get a scoped number before you commit to anything. No hourly billing for asking a question, because that is how firms stop asking.
We are just starting the firm. Is it too early?
It is the best time. Building the program alongside the registration costs less than retrofitting it after the first exam, and newly registered advisers are an explicit SEC examination priority for 2026 — the first look often comes sooner than founders expect.
We already have a compliance manual. Do we need you?
Maybe not. A manual is a document; a compliance program is a document plus the review, testing, records, and evidence that it is actually being followed. The most common finding at small firms is not a missing manual — it is a good manual nobody can show they used.
The gap assessment tells you which one you have. If the answer is that you are in decent shape, we will tell you that.
What happens if we get an exam notice?
You forward it to us the day it arrives. We build the document production, prepare you and your team for interviews, sit in where appropriate, and draft the responses. If a deficiency letter follows, we write the remediation plan and then execute it.
Do you work with advisers outside your state?
Yes. We work with SEC-registered and state-registered advisers nationwide, including firms registered in multiple states. The work is remote by design; the documentation and the calendar do not care where anyone sits.
Who is doing the work?
A dedicated team, assigned to your firm, that you will know by name. We are deliberately not a marketplace that rotates you through whoever is available, and deliberately not a piece of software that hands you a checklist and calls it a program.
The intent is that you rarely have to think about us. That is the whole product.