The SEC expects investment advisers to be prepared for the death or sudden departure of key personnel. The SEC’s settled enforcement action against a dually registered investment adviser and broker-dealer is a reminder of the importance of appropriate succession planning. The firm’s founder and CCO passed away in 2019, which coincided with an SEC examination of the adviser. The firm allegedly had failed to plan for the loss or incapacity of key individuals and lacked reasonably designed policies and procedures, particularly regarding its advisory business. The firm, which used an outsourced CCO following the founder’s death, allegedly failed to remedy many of those deficiencies by the time of a subsequent examination in 2021. This article details the SEC’s allegations and the multiple compliance deficiencies that gave rise to the enforcement proceeding. See our three-part succession planning series: “Why Fund Managers Must Review Their Positions on Succession Planning and CCO Outsourcing” (Jun. 7, 2018); “What Fund Managers Should Consider When Hiring and Onboarding CCOs; Determining CCO Governance Structures; and Evaluating Risks of CCO Turnover” (Jun. 14, 2018); and “A Succession-Planning Roadmap for Fund Managers” (Jun. 21, 2018).