The SEC instituted administrative proceedings against Rudney Associates, Inc., a registered investment adviser to retail clients that managed approximately $869 million in assets, and its founder and CEO, Eric A. Rudney, for multiple long-standing compliance failures, including recidivist violations identified in multiple SEC examinations and a prior SEC enforcement action. Violations included 1) failing to obtain and provide to examiners signed investment advisory agreements with clients; 2) failure to adopt and implement effective compliance policies and procedures; 3) failure to conduct an annual compliance review; 4) disclosure failures in Form ADV related to its advisory fees; and 5) failure to document delivery of Form ADV Part 2A to clients and prospective clients. The case highlights RIA obligations under the Compliance Rule and potential and SEC examiner expectations. It is critical that investment advisers of all sizes, take their compliance obligations and examination findings seriously and commit the necessary resources and diligence expected by SEC examiners to promptly and effectively correct deficiencies identified. Failing to do so can result in costly and damaging enforcement consequences.