Registered investment advisers face growing pressure to prove their compliance programmes are not just written down but actively working, and many are turning to outsourced chief compliance officers (OCCOs) to close the gap.
ACA outsourced chief compliance officer Shoshana Thoma-Isgur, who has worked as an SEC enforcement attorney, an in-house CCO, and now in an outsourced capacity, argues that firms fare better when compliance is treated as a core business function rather than a box-ticking exercise.
She notes that during her time at the SEC, shortfalls in firms’ programmes rarely stemmed from deliberate misconduct, but instead from weak structure, thin documentation or insufficient resourcing to match business growth. These gaps, she says, tend to snowball into longer examinations and heavier regulatory scrutiny.
The appeal of the OCCO model lies in timing: many advisers reach a stage where compliance obligations outpace what internal teams can manage, but a full-time CCO hire is not yet justified. Growth, new product launches, or expansion into unfamiliar markets are typical triggers. An OCCO offers experienced leadership without the cost of a permanent executive, alongside an outside perspective that can sharpen governance and risk management ahead of SEC exams.
ACA positions its OCCO offering around depth of bench strength, drawing on specialists across regulatory reporting, cybersecurity, private funds, marketing compliance and ESG, rather than relying on a single individual. The firm says this structure lets clients tackle complex, cross-cutting compliance issues more efficiently, while embedding processes into day-to-day operations rather than treating compliance as a separate function.
Examination readiness is central to the pitch. The SEC assesses whether compliance policies are reasonably designed, properly implemented, reviewed annually and adapted as a firm’s risk profile shifts. ACA’s OCCOs support clients through risk assessments, compliance testing, annual reviews, regulatory filings and the documentation trail examiners expect to see.
Independent oversight is framed as another advantage, giving management an external, objective voice that internal teams may struggle to provide, particularly when compliance decisions compete with other business priorities.
As firms scale, with new strategies, investors and operational complexity, the model is designed to free up executives who might otherwise be stretched across investment, operations and compliance duties simultaneously.
To read the full ACA post, click here.
Copyright © 2026 RegTech Analyst
Copyright © 2026 RegTech Analyst
