Investment advisers are required to, among other things, adopt and implement written compliance programs pursuant to Rule 206(4)‑7 under the Investment Advisers Act of 1940. Moreover, those programs must be specifically tailored to a manager’s business, including its strategy, structure and specific practices. Failing to customize the compliance program, such as by simply adopting an off-the-shelf program or manual, can result in deficiency letters and enforcement actions from regulators, as well as lost allocations from investors. This three-part series delves into the logistics of tailoring a fund manager’s compliance program. The first article outlines the expectations of the SEC, DOJ and investors as to the customization of compliance programs, as well as the consequences of failing to tailor those programs. The second article lays out what fund managers should consider when tailoring their programs, including the role of off-the-shelf programs. The third article identifies five triggers for a review – and possible update – of a manager’s compliance program. See “How Lawyers Can Leverage the Shifting Environment to Enhance Compliance Programs” (May 11, 2023).