A venture-backed investment technology company engaged InnReg to support the development and management of the compliance program for its SEC-registered investment adviser affiliate. The company operates in the fixed income and cash management space, using technology infrastructure to deliver algorithmically generated portfolio recommendations to third-party registered investment advisers.
The company has publicly reported significant scale, supporting firms representing more than $10 trillion in client assets and more than 50,000 financial advisors using or building on its investment management infrastructure. The platform is used by firms including Edward Jones, LPL Financial, and Hightower Advisors. In 2026, the company announced a more than $70 million Series C financing round, bringing total funding to over $130 million.
The client's advisory structure is built around a sub-advisory model centered on cash management and fixed income. Rather than serving retail clients directly, the RIA provides API-based cash management and fixed-income recommendations to third-party advisers, who may choose to implement them for their own end clients.
The platform supports scalable portfolio construction, rebalancing, execution coordination, and cash management and fixed-income allocation workflows through a technology-driven advisory structure.
Objective
The client’s objective was to develop and operate a compliance program aligned with its role as a technology-driven RIA operating under a limited discretionary authority framework. The firm needed a regulatory structure that supported its API-based sub-advisory model while reflecting its limited authority, the non-personalized nature of its recommendations, and the absence of direct retail client relationships.
The engagement focused on developing and managing the compliance program for an RIA structure supporting fixed-income and cash management services. This included policies and procedures, regulatory books and records, advertising review, firm and personnel registrations, code of ethics requirements, vendor management, information security, regulatory readiness, and compliance workflows tied to the client’s product and operating model.
The goal was to support the client’s ability to scale its fixed income and cash management offering through RIA channels while maintaining a compliance program that reflected its regulatory obligations, technology infrastructure, and sub-advisory role.
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Challenges
The client’s business model required careful alignment between investment adviser regulation and technology-driven delivery. As a sub-adviser providing algorithmically generated fixed income recommendations through APIs, the firm needed a compliance program that addressed advisory obligations without overstating the level of discretion, personalization, or client-facing responsibility involved in its model.
The structure also required clear separation between the client’s responsibilities as a sub-adviser and the responsibilities of the third-party advisers that maintain the end-client relationship. The compliance program needed to address how recommendations are generated, transmitted, reviewed, implemented, and documented, while recognizing that third-party advisers retain responsibility for deciding whether recommendations are appropriate for their clients.
Cash management and fixed income strategies introduced additional regulatory and operational considerations. The firm needed to account for trading and liquidity constraints, conflicts of interest, affiliated broker-dealer relationships, advertising claims, books and records obligations, vendor oversight, information security, and regulatory inquiry readiness.
Because the company operates through a highly automated infrastructure model, compliance also needed to fit inside existing product, engineering, legal, and operational workflows. The work required more than static policy drafting. It required practical compliance processes connected to the actual product, recommendation logic, technology stack, and business model.
InnReg's Solution
InnReg supported the development and management of the RIA compliance program, tailoring the work to the client’s sub-advisory structure, fixed income focus, cash management use case, and technology-driven operating model.
Compliance Program Development and Management:
Developed and maintained policies and procedures addressing the firm’s advisory activities, limited discretionary authority, fixed income recommendation process, personnel compliance, code of ethics requirements, regulatory books and records, and supervisory responsibilities.Sub-Advisory and Cash Management Framework:
Helped structure compliance workflows around the firm’s role as a sub-adviser to third-party RIAs, including the delivery of non-personalized, algorithmically generated fixed income recommendations through API-based infrastructure. The framework reflected the client’s limited authority to replace or withhold recommendations due to trading or liquidity constraints, rather than directly tailoring portfolios to individual end-client profiles.Product and Workflow Review:
Reviewed the business model, product design, recommendation delivery process, customer-facing workflows, internal escalation paths, and operating structure to identify compliance considerations tied to launch, scale, and ongoing product development.Advertising and Communications Review:
Reviewed marketing materials, product descriptions, website language, and related communications to address regulatory risks associated with describing automated fixed income, cash management, portfolio optimization, and advisory technology capabilities.Regulatory Operations and Oversight:
Supported firm and personnel registrations, regulatory books and records, continuing education, suspicious activity monitoring, regulatory calendars, and preparation for regulatory exams and inquiries. InnReg also advised on the impact of pending or newly enacted regulations and relevant federal and state enforcement developments.Technology, Vendor, and Information Security Controls:
Assisted with the development of vendor management and information security programs, including compliance-related review of vendors, partners, and technology workflows supporting recommendation generation, portfolio construction, rebalancing, and execution coordination.Embedded Compliance Support:
Provided ongoing compliance coverage across recurring obligations, product questions, reviews, escalations, documentation, regulatory deadlines, and compliance task tracking. InnReg’s role extended beyond periodic advisory input to support the day-to-day operation of the client’s compliance function.Compliance Workflow Design:
Developed customer-facing and internal compliance workflows to connect the firm’s regulatory obligations with its technology stack, product development process, and operational decision-making. This included support for supervisory design, compliance process optimization, and coordination between legal, compliance, product, technology, and business teams.
Client Results
The engagement provided the client with a compliance program tailored to its specific role as a technology-driven RIA and sub-adviser in the fixed-income and cash management markets. InnReg helped translate the firm’s regulatory obligations into policies, procedures, review processes, supervisory workflows, and recurring compliance activities that matched its API-based delivery model.
By structuring the program around limited discretionary authority, non-personalized recommendations, and third-party adviser implementation, the client gained a clearer operating framework for scaling fixed income and cash management services through RIA channels.
The work also supported the client’s ability to manage regulatory expectations across advertising, books and records, vendor oversight, information security, personnel compliance, regulatory calendars, and inquiry readiness. Because InnReg reviewed the product and operating model alongside the compliance documentation, the engagement helped connect regulatory requirements to the actual way the business develops, delivers, and manages its advisory technology.
The resulting compliance structure gave the client an embedded compliance function for a fast-growing investment technology platform serving large financial institutions, while allowing its internal team to continue focusing on product development, partnerships, and platform expansion.
How Can InnReg Help?
InnReg is a global regulatory compliance and operations consulting team serving financial services companies since 2013.
We are especially effective at launching and scaling fintechs with innovative compliance strategies and delivering cost-effective managed services, assisted by proprietary regtech solutions.
