


Year-End Compliance Review
Close the year with clarity — not unanswered questions.
Year-end is an opportunity to step back and confirm that your compliance program reflects the year you actually had — not the one you planned for. This resource helps SEC- and state-registered investment advisers take a measured, structured look at the year behind them and prepare confidently for the year ahead.
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This is about resolution, not remediation.
Why Year-End Is a Natural Review Point
By the end of the year, most firms have absorbed changes quietly — new clients, refined workflows, adjusted supervision, evolving disclosures, or shifting priorities. Individually, these changes may feel manageable. Collectively, they shape how regulators view your compliance program.
A year-end review allows you to:
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confirm documentation reflects the year that actually occurred
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identify gaps before they roll into the next cycle
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reduce uncertainty heading into exams, renewals, and reporting obligations
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It’s a pause designed to restore alignment — not create extra work.
What a Year-End Compliance Review Focuses On
This resource emphasizes reflection and consistency rather than checklists or deadlines.
High-level focus areas:
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Whether policies and procedures still align with operations
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How supervision and oversight were evidenced throughout the year
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Consistency across disclosures, records, and real-world practice
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Issues that can be resolved cleanly now, rather than carried forward
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The goal is clarity — knowing what’s solid, what needs attention, and what can wait.
Common Year-End Patterns We See
As the year closes, firms often discover patterns that weren’t obvious month-to-month:
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Documentation that no longer reflects current processes
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“Temporary” workarounds that became permanent
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Oversight responsibilities that shifted without formal updates
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Disclosures that lagged behind business evolution
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Items deferred in favor of client or operational priorities
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Recognizing these patterns early allows for thoughtful resolution — rather than rushed fixes in the new year.
How to Use This Resource
This page is designed as a year-end anchor — a place to frame thoughtful review conversations and support decision-making.
It may be used to:
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guide an internal year-end compliance discussion
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support engagement with a compliance consultant
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inform planning for the upcoming year
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reduce exam-related uncertainty
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Like the other resources in this section, it is intentionally evergreen and will continue to evolve.
Is a Year-End Compliance Review Right for You?
This resource is particularly relevant if:
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your firm changed or grew during the year
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documentation updates were deprioritized in favor of execution
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you want to enter the new year with fewer open questions
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you prefer proactive alignment over reactive clean-up
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Closing the year well often makes the next year easier.
A Calm, Adviser-Focused Perspective
Three Lumos Consulting works with independent and solo advisers who value proportionate, practical compliance support. A year-end review is not about perfection — it’s about reasonable alignment, defensible decisions, and reduced friction going forward.
This resource will continue to evolve.
Additional insights will be added to reflect year-end regulatory expectations and practical steps advisers can take to simplify the next compliance cycle.