Fractional compliance for independent RIAs
Senior-level compliance support, priced for independent advisory firms, whether you're registered with your state or the SEC. ComplyMint handles your filings, reviews and testing on a set calendar. Your CCO stays in charge, and your file is ready when the exam letter arrives.
See it in 90 seconds
Every task, form and record in one secure place, with reminders before anything is due and every submission filed as a signed PDF. Here is how it works, start to finish.
Why it matters
Examiners don't grade on a curve for firm size. Every firm is expected to have written policies, documented reviews and accurate filings, whatever its size. Most deficiencies come from missing paperwork and missed deadlines.
An exam opens with a document request: your annual review, personal trading reports, fee calculations, advertising and complaint log. If it isn't written down and dated, it didn't happen.
Holdings reports by January 10, transaction reports 30 days after every quarter-end, the ADV amendment within 90 days of year-end, and 12 IAR CE credits by December 31. One missed item becomes a finding.
SEC-registered firms already follow the Marketing Rule, and in May 2026 NASAA adopted amendments that bring state rules in line, including net-of-fee returns whenever gross returns are shown. States are adopting them one at a time.
Every hour your CCO spends on forms is an hour away from clients. A steady outside resource keeps the work moving without adding a full-time hire.
My job is to take compliance off your plate. I keep your program current and your deadlines met, so an exam letter becomes a request for documents you already have.
Services
Every service ends in a written report built from the same standard template, so your compliance file looks consistent year after year.
A written report with findings, fixes and sign-off. We test your policies against actual practice, sample client files and agreements, and check fee billing, personal trading, custody, marketing, cybersecurity, continuity and ADV accuracy.
Part 1A, Part 2A, each advisor's 2B, the summary of material changes, and the IARD submission. Your firm reviews, approves and pays the filing fees.
Reviewed against the rules that apply to your firm, state or SEC, and redlined every year so it matches how your firm actually operates. Your firm approves and signs off.
Every access person trade is compared with client trades in the same security, five trading days either side. We track holdings and transaction reports and the IPO and private placement approval log.
Every quarter we review a risk-based sample of advisor email, texts and social messages, plus keyword searches for complaints, guarantees and off-channel activity. Each review is documented with the sample, search terms, findings and how flags were resolved.
Twice-a-year checks of your website, social posts, testimonials, ratings and advertising, including net-of-fee performance and social media archiving.
Two live sessions a year for your team, with attendance, make-ups and signed attestations documented for your file.
We act as the examiner: a 24-item document request, a five-day production window, staff interviews, a 100-point readiness score and a sample deficiency letter.
When a real exam letter arrives, we prepare documents and draft responses. Your CCO stays the point of contact with the regulator.
A side-by-side plan versus IRA analysis. You supply the numbers and we produce the report. The recommendation remains the advisor's.
One-time setup of the fiduciary acknowledgment and rollover best-interest disclosure required under DOL PTE 2020-02, plus Form CRS where your state requires it. Included in your monthly fee.
Every finding gets an owner, a target date and evidence of completion. We track license renewals and fees and give you notice; your firm submits and pays.
Sample reports
These excerpts come from our sample annual report for Harborline Wealth Partners, a fictional $48M firm. Every client report uses the same templates.
Harborline's compliance program is reasonably designed and generally effective, with 12 findings: none critical, 3 high, 5 moderate and 4 low. All prior-year findings were closed.
| # | Finding | Report | Severity | Target |
|---|---|---|---|---|
| F-1 | Access Person B's annual holdings report filed 34 days late | Code of Ethics | High | Dec 15 |
| F-2 | Website shows gross-of-fee returns without net-of-fee returns | Marketing | High | Nov 30 |
| F-3 | Private placement bought before written pre-approval | Code of Ethics | High | Dec 15 |
| F-4 | Incident response plan missing state breach-notification steps | Cybersecurity | Moderate | Feb 28 |
| F-5 | Annual privacy notice not delivered to 6 clients | Privacy | Moderate | Dec 31 |
| F-6 | One rollover lacks a documented plan-vs-IRA analysis | Rollovers | Moderate | Dec 31 |
| Access person | Report type | Received | Trades | Accounts |
|---|---|---|---|---|
| A | Quarterly transaction report | Oct 16 | 16 | 3 of 3 |
| B | Quarterly transaction report | Oct 22 | 10 | 2 of 2 |
| C | Quarterly transaction report | Oct 12 | 15 | 2 of 2 |
| D (CCO) | Quarterly transaction report | Oct 7 | 2 | 2 of 2 |
| E | Duplicate broker statements | Oct 6 | 3 | 1 of 1 |
| Access person trade | Client trades (±5 days) | Result |
|---|---|---|
| Jul 8 · A · Buy 25 GLD @ $301.60, 3:45 pm | Same day, 9:50 am · 1,150 sh in 30 accounts @ $300.95 | Pass |
| Aug 27 · E · Buy 10 VTI @ $331.20 | Aug 28 · 190 sh in 2 accounts (new money) | Cleared |
| Sep 15 · C · Buy 80 SCHD @ $28.10 | Sep 21 · 3,050 sh in 26 accounts (model change approved Sep 17) | Cleared |
| Area | Score | Points |
|---|---|---|
| Books and records production | 18 / 20 | |
| Disclosures and filings | 15 / 15 | |
| Code of Ethics | 10 / 15 | |
| Advertising | 6 / 10 | |
| Client files, fees, custody | 19 / 20 | |
| Cybersecurity, privacy, continuity | 12 / 15 | |
| Staff interviews | 4 / 5 |
"During the examination, staff identified the following deficiencies. (1) The firm's website presents performance gross of advisory fees without corresponding net-of-fee performance. (2) An access person acquired a limited offering before obtaining the firm's approval. (3) An access person failed to submit an annual holdings report when due."
72 of 73 marketing pieces met the firm's advertising policy. The website performance page shows returns before fees only (F-2, High), and LinkedIn comments are not being archived (F-11, Low).
| Type | Count | Passed | Issues |
|---|---|---|---|
| Website pages | 9 | 8 | Gross-only performance |
| Quarterly client newsletters | 4 | 4 | — |
| LinkedIn posts | 38 | 38 | Comments not archived |
| Facebook posts | 12 | 12 | — |
| Seminar deck and email campaigns | 7 | 7 | — |
| Business cards and letterhead | 3 | 3 | — |
| Test | Result |
|---|---|
| Net of fees shown whenever gross is shown | Fail |
| Performance periods balanced (1, 5, 10 years or since inception) | Pass |
| Third-party ratings: criteria and fees disclosed | Pass |
| No guarantees or promissory language | Pass |
| Professional designations accurate and current | Pass |
| # | Action | Owner | Target | Evidence | Status |
|---|---|---|---|---|---|
| F-2 | Add net-of-fee returns to website or remove page | CCO + marketing | Nov 30 | Screenshot and workpaper | In progress |
| F-3 | Written warning; written-only pre-approval in Code | CCO | Dec 15 | Warning letter; adopted Code | Done |
| F-1 | Automated holdings-report reminders | CCO | Dec 15 | Reminder schedule | In progress |
| F-10 | Update custodian references in P&P manual | ComplyMint | Dec 15 | Adopted manual | In progress |
| F-5 | Deliver privacy notice to 6 households | Operations | Dec 31 | Delivery log | Not started |
| F-6 | Complete and sign rollover analysis | IAR + ComplyMint | Dec 31 | Signed analysis | Not started |
The complete Harborline sample runs 38 pages. Ask for a copy on your intro call.
A year with ComplyMint
This is the 2027 calendar from our sample report, for a firm with a December 31 fiscal year-end. Each item shows who owns it.
Every other month: CCO check-in call and open-item review.
Dates shift for a non-December fiscal year-end and for your regulator's rules. Access persons must submit quarterly transaction reports within 30 days after each quarter ends; the trade surveillance review follows the next month. Communications for each quarter are reviewed in the first month of the next quarter.
Pricing
No tiers to compare and nothing extra to decide on. Every client gets the full program.
Continuous support between calls, with replies within 1 business day. We do not meet with regulators for you. Filing and license fees are paid by your firm.
About
Founder, ComplyMint, LLC
I started my career as a financial advisor, so I know what compliance feels like from the advisor's chair. From there I moved to the corporate side at New York Life as Director of Standards, where I spent five years on supervision and standards for a large field force.
Most recently I served as Chief Operations & Compliance Officer of Old Point Wealth Management, N.A., an OCC-regulated national trust company. I ran its policies and procedures, account reviews, BSA and OFAC reviews, personal trading oversight and regulatory filings, and I led its audits and OCC exams.
I stepped away from that executive role for one reason: my family relocated to be closer to my wife's family. Consulting lets me keep doing the work I'm good at, now for independent advisory firms that need an experienced compliance resource without a full-time hire.
FINRA licenses previously held (not currently active)
Book a quick intro call. We'll talk through where your program stands today and what we'd take off your plate, and I'll send you the full sample annual report. No cost and no obligation.