A compliance calendar for small RIAs: what recurs monthly, quarterly and yearly
A compliance calendar is a single list of every recurring task a firm owes, each with its frequency, due date, owner and the record that proves it was done. For a small RIA it usually covers monthly items like reconciling accounts and reviewing the complaints log, quarterly items like fee billing and personal securities reports, and annual items like the Form ADV amendment, brochure delivery and the review of written procedures. Your compliance consultant should confirm the list for your firm.
In a small firm the person who meets clients is often the same person who runs billing and acts as chief compliance officer. The work gets done, mostly. What slips are the tasks that come round once a quarter or once a year, because nobody remembers exactly when they last happened. A calendar with owners and evidence fixes that.
What is a compliance calendar for?
A compliance calendar is there so that any recurring task can be answered with a date and a record, not a memory. It does two jobs. Before a task is due, it reminds the owner. After it's done, it points to the evidence. The second job is the one most firms skip, and it's the one that matters when someone asks what you did last year.
What should each calendar entry include?
Each entry needs enough detail that someone other than you could do the task and file it. In practice that means:
- The task, in plain words.
- Frequency and due date.
- Owner.
- The date it was actually done.
- The record kept, and where it is filed.
What recurs monthly, quarterly and yearly?
Most small RIAs end up with a short monthly list, a medium quarterly list and a longer annual list. A typical layout:
| Frequency | Examples | Record |
|---|---|---|
| Monthly | Reconcile firm bank accounts; review the complaints and incidents log; check new accounts are assigned to a strategy | Sign-off with date |
| Quarterly | Advisory fee billing; personal securities transaction reports from access persons; model and drift review | Billing file; reports received; review notes |
| Annually | Form ADV annual amendment; brochure delivery or offer; holdings reports; suitability reviews due; annual review of written procedures; vendor reviews | Filing confirmation; delivery records; review memo |
| As needed | ADV updates when information becomes inaccurate; new hire onboarding; client terminations | Dated notes |
Which dates are set by rule?
Several of the annual and quarterly dates come straight from SEC rules. These apply to SEC-registered advisers; state-registered firms should check their own state's rules, which may set different dates.
| Task | SEC timing | Source |
|---|---|---|
| Form ADV annual updating amendment | Within 90 days of fiscal year end | 17 CFR 275.204-1 |
| Annual brochure delivery or summary of material changes | Within 120 days of fiscal year end, if the brochure has materially changed | 17 CFR 275.204-3 |
| Personal securities transaction reports | No later than 30 days after quarter end | 17 CFR 275.204A-1 |
| Personal securities holdings reports | At least once each 12 months | 17 CFR 275.204A-1 |
| Review of compliance policies and procedures | No less frequently than annually | 17 CFR 275.206(4)-7 |
Rule text checked on the Legal Information Institute site in October 2026. Confirm every date against the rules that apply to your firm.
How would a small firm set one up?
Take a hypothetical solo RIA with about 60 households and a December fiscal year end. The owner is also the chief compliance officer, and a part-time assistant helps with billing.
The owner builds a spreadsheet with one row per task. Monthly reconciliation and the complaints log review go to the owner, due the 10th of each month. Quarterly billing goes to the assistant, due in the first week after quarter end, with the owner signing off the fee file. The owner's own quarterly transaction report is due 30 days after quarter end, so it gets its own row even though only one person reports.
The annual items cluster in the first months of the year. With a December year end, the SEC-rule dates above land at the end of March for the ADV amendment and the end of April for brochure delivery. The owner puts the procedures review in February, before both, so any change to procedures can be reflected in the filing. Suitability reviews are spread across the year by client anniversary instead of being crammed into one month.
Each row has a column for "where the evidence is". After the first year, that column alone tells the owner which records exist and which were never filed.
Why keep the evidence next to the task?
A tick on a calendar proves nothing later. Keep the record with the task: the billing file, the reports received, the review memo. Then the calendar doubles as an index of your evidence, and producing last year's records means reading down one column.
When is this overkill?
A one-person firm doesn't need software for this, or a 40-row list on day one. Start with the rule-driven dates in the table above and the monthly reconciliation, then add rows as you notice tasks recurring. The calendar should match what your firm actually does. A long list copied from a template that nobody follows is worse than a short one that's kept.
How does Advorra support a compliance calendar?
Advorra keeps the records a calendar points to in one place: compliance registers, the suitability-review clock, dated strategy changes, billing runs and documents, all in the firm's own workspace. The calendar tells you when; Advorra is where the evidence sits. To see the registers your calendar would point to, visit the product page, or read written procedures for small RIAs for the procedures your annual review covers.
A practical layout, not legal or compliance advice.
Questions advisors ask
What should I do if I miss a date on the calendar?
Do the task as soon as you notice, record the date it was actually done, and write a short note on why it was late and what you changed. A dated late record is far easier to explain than a gap.
Should the calendar be a spreadsheet or a calendar app?
Either works. A spreadsheet is better as a record because each row can hold the owner, the due date, the date done and where the evidence is filed. A calendar app is better for reminders. Many small firms use both, with the spreadsheet as the record.
When is the Form ADV annual updating amendment due?
For SEC-registered advisers, within 90 days of the end of the fiscal year under Rule 204-1. State-registered advisers should confirm their state's requirements.
Who should own the calendar?
The chief compliance officer, even in a one-person firm. Each task should still name who does it.
Is this compliance advice?
No. It is a practical layout. Your regulator's rules and your compliance consultant determine what goes on your calendar.
See it on a demo firm
Advorra is practice software for independent RIAs: clients, models, IPS, billing and compliance records in one place, on top of the custodian you already use. Built by The CollabHub.
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