How an OCCO Helps RIAs Strengthen Regulatory Confidence

ACA OCCO Shoshana Thoma-Isgur shares her perspective on building effective compliance programs, drawing on her experience as an SEC enforcement attorney, in-house CCO, and outsourced CCO.

For RIAs, compliance has never been more important—or more complex. As the SEC continues to scrutinize firms’ compliance programs, advisers are expected to demonstrate that their policies, procedures, and controls are not only documented but actively implemented and tailored to the firm’s risks.

Having served as an SEC enforcement attorney, an in-house CCO, and now as an ACA OCCO, I’ve experienced the compliance process from multiple perspectives. One lesson has remained constant throughout my career: Firms can better demonstrate the effectiveness of their compliance programs when they treat compliance as an integral business function rather than solely as a regulatory requirement.

During my time at the SEC, I often encountered firms whose compliance programs fell short not because they engaged in misconduct but because their programs lacked structure, documentation, or sufficient resources to keep pace with the business. Those shortcomings frequently resulted in additional questions, expanded document requests, longer examinations, and unnecessary regulatory scrutiny.

Today, in my role as an ACA OCCO, I help firms identify and address those gaps before they lead to examination findings, deficiency letters, or enforcement referrals. Effective compliance means building a practical, risk-based program that demonstrates a firm’s commitment to fulfilling its fiduciary obligations.

Why More RIAs Are Choosing the OCCO Model

Many investment advisers reach a point where compliance demands exceed their internal resources, yet hiring a full-time CCO isn’t the right solution. Whether they’re growing rapidly, launching new products, expanding into new markets, or seeking greater regulatory confidence, these firms often benefit from an OCCO.

An OCCO provides experienced compliance leadership without the overhead of a full-time executive while bringing an independent perspective that helps strengthen governance, improve risk management, and prepare firms for SEC examinations.

What Sets an ACA OCCO Apart?

Regulatory Experience That Matters

ACA’s OCCOs include former regulators, experienced in-house compliance officers, and seasoned industry professionals who understand how SEC expectations translate into practical business solutions. Our professionals have experience on both sides of the examination process, helping clients anticipate regulatory concerns before they arise.

A Team Behind Every Engagement

One of the greatest advantages of partnering with ACA is that you’re not relying on a single individual. Every OCCO is supported by the industry’s largest compliance consulting organizations, providing access to specialists in regulatory reporting, cybersecurity, private funds, marketing compliance, ESG, and other emerging regulatory issues. That depth of expertise enables clients to address complex compliance challenges efficiently.

Compliance That Integrates with Your Business

Strong compliance programs don’t operate in isolation. They become part of how a firm conducts business every day.

ACA OCCOs work closely with executive leadership and business teams to build compliance processes that are practical, scalable, and aligned with the firm’s operations. Rather than creating unnecessary complexity, we help firms establish sustainable controls that evolve alongside their business.

Examination-Ready Compliance Programs

SEC examinations may assess whether a firm’s compliance policies and procedures are reasonably designed, effectively implemented, reviewed at least annually, and adapted to changes in the firm’s business and risks.

ACA OCCOs help firms prepare by supporting:

• Risk assessments
• Compliance testing
• Annual reviews
• Regulatory filings
• Policy and procedure updates
• Documentation that supports examination readiness

The result is a compliance framework that is organized, defensible, and prepared for regulatory scrutiny.

Independent Oversight

As an external compliance leader, an OCCO provides objective guidance that internal teams may not be able to provide. Independent oversight helps management identify emerging regulatory risks, strengthen internal controls, and make informed compliance decisions without being influenced by competing business priorities.

Scalable Support for Growing Firms

As firms grow, their regulatory obligations become more complex. New investment strategies, additional investors, expanded operations, and evolving SEC requirements all require a more sophisticated compliance infrastructure.

Allowing Leadership to Focus on Growth

In many firms, compliance responsibilities fall to executives already responsible for investments, operations, finance, or business development. Although this structure may be appropriate for some firms, it can stretch resources and create compliance challenges as the business grows.

An OCCO provides dedicated compliance leadership, allowing executives to focus on growing the business while providing dedicated resources for the administration of the compliance program.

Building Regulatory Confidence Before the SEC Arrives

Examination readiness is developed before an SEC examination begins through effective implementation, testing, documentation, and ongoing review of the compliance program.

The firms that consistently navigate examinations successfully share common characteristics: experienced compliance leadership, proactive risk management, comprehensive documentation, and a culture that treats compliance as an integral part of the business.

The SEC has consistently emphasized that chief compliance officers should be competent, knowledgeable, empowered, and provided with sufficient authority and resources to administer and enforce an effective compliance program.

By combining deep regulatory experience with practical business insight and the resources of a leading compliance consulting firm, we help clients build compliance programs that are resilient, examination-ready, and aligned with their business objectives.

Is Your Compliance Program Ready for Your Next SEC Examination?

Whether your firm needs ongoing compliance leadership, additional support for an existing CCO, or guidance on preparing for an SEC examination, ACA’s OCCOs provide practical, risk-based solutions tailored to your business.

Contact ACA today to learn how an OCCO can help your firm strengthen compliance, reduce regulatory risk, and build lasting regulatory confidence.