Advisers must take seriously their duties to adopt appropriately tailored compliance policies and procedures, as well as codes of ethics. To that end, the use of boilerplate documents is sure to draw SEC scrutiny. In a recent settled enforcement proceeding against an adviser as well as its founder and CCO, the SEC asserted the adviser used inappropriate off-the-shelf policies that were not tailored to its own business and clients; failed to conduct annual compliance reviews; adopted an inadequate code of ethics; and failed to file and post Form CRS by the applicable deadlines. The SEC also claimed the CCO was responsible for all of the firm’s compliance failures. This article details the SEC’s allegations and the terms of the settlement. See “SEC Action and Commissioner Peirce’s Statement Shed Light on CCO Liability” (Oct. 4, 2022); and our two-part series “Thirteen Questions an Adviser’s Principals Should Ask Compliance” Part One (Mar. 29, 2022) and Part Two (Apr. 5, 2022).