CE Credit Course: Outsourced CCO (OCCO) Services for RIAs
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In the current regulatory climate, Registered Investment Advisers (RIAs) face a difficult choice: stretch internal resources to the breaking point or risk a deficiency letter from the SEC. For many, the traditional in-house Chief Compliance Officer (CCO) model is becoming an operational bottleneck.
To address these challenges, AdvisorLaw’s senior compliance experts, Dave Reichert and Janet Messer, were recently invited by the Financial Experts Network (FEN) to present a deep-dive webinar: “Outsourced Chief Compliance Officer (OCCO) Services for Registered Investment Advisers.”
Watch the Webinar Replay & Earn CE Credit
Is Your CCO a Resource—or a Bottleneck?
As the SEC moves toward more aggressive enforcement in 2026, the complexity of compliance—from Regulation S-P data protection to Anti-Money Laundering (AML) protocols—is at an all-time high.
During the presentation, Dave Reichert and Janet Messer highlighted why firm founders are increasingly moving away from the "Dual-Hat" CCO model (where a partner serves as CCO) in favor of the Outsourced CCO (OCCO) framework.
Why RIAs are Switching to the OCCO Model:
- Cost-Effective Scalability: Access elite, senior-level compliance oversight without the $500k+ salary and benefits package of a full-time, in-house CCO.
- Neutral Third-Party Objectivity: Internal compliance can create friction between partners. An OCCO provides objective enforcement, preserving firm culture while making sure that regulatory standards are met.
- Audit Readiness: Move from "reactive" compliance to a "proactive" defensible framework.
- Resource Optimization: Allow your lead advisors to focus on client acquisition and portfolio management rather than dense regulatory filings.
Expert Insights: Dave Reichert & Janet Messer
As Senior Compliance Analysts at AdvisorLaw, Dave Reichert and Janet Messer bring decades of combined experience in navigating the SEC and state regulatory landscapes. Their approach focuses on building a "living" compliance program—one that grows with your firm rather than acting as a handbrake on your success.
In this course, they break down:
- The Legal Framework: How the SEC views outsourced CCO arrangements.
- Implementation: How to transition from a consultant-led model to a fully integrated OCCO.
- Risk Management: Identifying subtle operational risks before they become liabilities during an exam.
Earn Your IAR CE Credits Today
Staying compliant is a year-round job, and maintaining your registration is no different. This course is approved for IAR Continuing Education (CE) credit through our partnership with the Financial Experts Network.
Mandatory CE Reminder: If you are an IAR in a state that has adopted the NASAA Model Rule, you must complete 12 hours of CE annually. Don't fall into "CE Inactive" status—use this expert-led session to stay ahead of your 2026 requirements.
FAQ: Outsourced CCO Services for RIAs
Can an RIA legally outsource the CCO role?
Yes. The SEC allows RIAs to engage an outsourced CCO, provided the firm maintains ultimate responsibility for its compliance program and the OCCO has sufficient authority and resources to perform the role.
What is the difference between a compliance consultant and an OCCO?
A consultant typically provides advice and templates, but the advisor still executes the work. An OCCO takes a much more active role in managing the compliance calendar, testing protocols, and overseeing the firm's regulatory filings.
How does an OCCO help during an SEC audit?
An OCCO acts as the primary point of contact for examiners, providing the documented audit trail and "defensible framework" required to satisfy SEC scrutiny.
Ready to Fortify Your Firm?
Beyond CE credits, AdvisorLaw provides the turn-key OCCO solutions discussed in this webinar. We handle the heavy lifting of compliance so you can lead your firm with total peace of mind.
Engage with our experts today!