On September 14, 2026, the SEC's Division of Examinations published a Risk Alert summarizing staff observations from recent examinations regarding investment advisers' annual reviews of their compliance policies and procedures under Rule 206(4)-7. The Division identified recurring issues with the timeliness of reviews, the completeness of review procedures, alignment between policies and actual practices, documentation, and follow through on corrective actions. Our latest client alert outlines the specific deficiencies the staff identified, what this means for RIAs and their CCOs, and how Standish can help firms ensure their annual review process meets SEC standards before their next examination.