Rule 206(4)-7 deems it fraudulent for a registered adviser to provide advice unless it has adopted and put into effect written procedures that can reasonably be expected to prevent breaches of the Act and rules by the firm and the people it supervises, reviews them no less than annually for adequacy and effectiveness, and designates a chief compliance officer responsible for administering them. The SEC's adopting release names the areas the policies should address: portfolio management, trading, proprietary and personal trading, accuracy of disclosures, safeguarding client assets, record-keeping, marketing, valuation and fees, privacy and business continuity. The annual review documentation is a rule 204-2 record, and the SEC has proposed requiring a written annual review report.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.