The need for an adviser to have an effective compliance program cannot be overstated. In many SEC-settled enforcement proceedings, the only violation alleged is the adviser’s failure to comply with Rule 204(4)‑7 under the Investment Advisers Act of 1940 – the Compliance Rule. To assist advisers in navigating their obligations under that rule, an ACA Group program addressed the fundamental elements of compliance programs; use of gap analysis and risk assessments to create an effective program; testing and documentation; and qualifications of CCOs and compliance staff. The article synthesizes the program’s key takeaways. See “Overview of the SEC’s Standards for Resilient and Effective Compliance Programs and Fiduciary Practices (Part Two of Two)” (Feb. 2, 2023).