Outsourced Chief Compliance Officer

Outsourcing your CCO gives you access to specialized expertise and regulatory insight in a way that can be more efficient and cost-effective than hiring a full-time, in-house CCO—especially for growing firms. You also avoid the challenges of recruitment, onboarding, and staff turnover. An outsourced CCO brings a fresh, independent perspective to your compliance program and helps ensure you stay ahead of regulatory changes.

• Cost efficiency: Outsourcing can be a more practical and affordable option than hiring a full-time executive, especially for firms looking to manage expenses while maintaining high standards.
• Expertise: Gain access to experienced professionals with deep knowledge of SEC regulations and industry best practices.
• Flexibility: Outsourcing your CCO offers a flexible solution that provides added leverage during periods of growth, internal compliance turnover, or when specialized expertise is needed. It’s not a permanent commitment, support can be tailored to your firm’s evolving needs and regulatory complexity.
• Risk management: Strengthen your compliance posture in an effort to reduce the likelihood of regulatory breaches or penalties.
• Focus on core business: With compliance managed by trusted experts, your leadership team can stay focused on clients, investors, and business strategy.

An outsourced CCO acts as a strategic partner in managing your firm’s regulatory obligations and strengthening your compliance framework. Their responsibilities typically include:

• Developing, implementing, and maintaining your compliance program.
• Conducting risk assessments, annual reviews, and on-site evaluations.
• Ensuring adherence to SEC (including Rule 206(4)-7 of the Investment Advisers Act).
• Providing employee training on regulatory topics, including your Code of Ethics.
• Reporting on compliance matters to senior management and the board.
• Overseeing regulatory filings such as Form ADV and supporting SEC exam readiness.

Outsourcing may be the right fit if your firm is facing complex regulatory demands, rising compliance costs, or limited internal resources. A consultation with our team can help determine if outsourcing is the right fit for your needs.

Outsourcing the CCO role is permitted by the SEC, but it must be done with care. Regulatory expectations remain the same whether the role is internal or outsourced. That’s why we ensure that any outsourced CCO we provide has the authority and access needed to perform their duties effectively.

To be successful—and meet regulators’ and investors’ expectations—an outsourced CCO must have a meaningful presence at the firm, a strong understanding of its operations, and a position of seniority to implement and enforce policies. At ACA, we work closely with clients to ensure these conditions are met from day one.

An outsourced CCO acts as an extension of your business—working closely with your leadership and operational teams to embed compliance into day-to-day operations. They provide guidance, implement procedures, and report to senior management, ensuring your program runs smoothly and remains aligned with regulatory expectations.  To be effective, our CCOs must have a seat at the table and be in a position to implement and enforce the firm’s policies and procedures. 

Yes, an outsourced CCO plays a critical role in helping your firm prepare for and respond to regulatory exams and audits. They assist with document readiness, interview prep, coordinate communication with examiners, and help ensure your compliance program meets regulatory expectations throughout the process. It is our job to get your firm through the exam as seamlessly as possible.

For enhanced SEC exam preparedness, ACA also offers Mock SEC Examinations delivered by a team of former regulators, CCOs, and industry experts. Our approach mirrors the SEC’s data-driven exam style—including document requests, interviews, and trade analysis—and incorporates advanced analytics powered by ComplianceAlpha^®, modeled on the SEC’s own National Exam Analytics Tool (NEAT).

Start by evaluating whether the CCO has experience with firms like yours and understands the specific regulations that apply to your business. Look for someone with a strong grasp of SEC requirements, depending on your registration status, and a proven track record managing compliance programs. Just as importantly, make sure they align with your firm’s culture and communication style—a good fit leads to a stronger, more collaborative partnership.

Yes, your outsourced CCO actively monitors regulatory developments, industry trends, and rule changes. They’ll update and manage your compliance program as needed to help ensure your firm stays aligned with evolving requirements and expectations, as they apply to your business. 

Communication with your outsourced CCO can take place through regular meetings, reports, and updates. Your outsourced CCO will work with you to establish a cadence of regularly scheduled meetings to discuss and review the compliance program, risks, and strategies. In addition, you can contact your outsourced CCO at any time as compliance issues or questions arise.

The cost of outsourcing a CCO varies based on your firm’s size, regulatory complexity, and the level of support required. For most firms, outsourcing the title can be a fraction of the cost of a dedicated CCO and offers a more flexible and efficient option than hiring a full-time, in-house CCO, particularly when access to deep expertise and scalable support is a priority. 

We can assume the title and get started right away. The initial onboarding process, including conducting a risk assessment of the current compliance program, reviewing existing policies and procedures, identifying potential gaps, and beginning to implement necessary changes will take a few weeks.

If an outsourced CCO identifies gaps or risks, they will provide a detailed assessment and action plan to address these issues. They will work with your team to implement corrective measures designed to ensure ongoing compliance. To be effective, they must have a position of seniority within the firm.

If you’re exploring outsourced CCO support, we’re here to help. Our team will work with you to understand your needs and recommend a tailored solution that fits your firm’s structure, regulatory obligations, and growth plans. Contact us to start the conversation and learn how our OCCO services can support your compliance program.