Rule 206(4)‑7 under the Investment Advisers Act of 1940 requires registered investment advisers to evaluate, at least annually, the adequacy of their compliance policies and procedures and the effectiveness of the compliance program’s implementation. The SEC has focused on the annual compliance program review requirement in its examinations and enforcement actions. For example, a November 2020 risk alert on compliance issues observed in investment adviser compliance programs noted that SEC exam staff “observed advisers that were unable to demonstrate that they performed an annual review or whose annual reviews failed to identify significant existing compliance or regulatory problems.” See “Risk Alert on Compliance: Inadequate Annual Reviews, Poorly Implemented Policies and Other Key Takeaways (Part Two of Two)” (Feb. 25, 2021). This two-part series is structured as a checklist that investment advisers’ CCOs can adapt and use to streamline and organize their annual reviews. The first article analyzes Rule 206(4)‑7 and sources of guidance on complying with the rule; spells out who should be involved in conducting an adviser’s annual compliance program review, what information should be gathered for review and what areas should be covered; and notes the questions that SEC examiners are likely to ask about an adviser’s annual review during an examination – which advisers should be able to answer after having conducted their reviews. The second article provides a non‑exhaustive list of the questions advisers should answer for each substantive area covered in the review. See “Lax Annual Compliance Review Procedures May Draw SEC Enforcement Action” (Nov. 17, 2016).