A large U.S.-based financial technology company engaged InnReg to support the SEC registration process, pre-launch compliance program development, and planned ongoing compliance management of an affiliated registered investment adviser. The client operates a technology platform that provides businesses with a range of financial and operational tools.
The company operates at significant scale, serving tens of thousands of business customers and processing more than $100 billion in annualized transaction volume. It has generated more than $1 billion in annual revenue and raised several billion dollars in equity financing, establishing it as one of the larger privately held fintech companies in the US.
As part of its product expansion strategy, the client was establishing an affiliated RIA to support an investment-related offering for its business customers. The offering was designed to bring investment-related products to companies through the platform, with the RIA serving as the investment adviser. This placed the management of customer cash within an advisory framework and introduced obligations under the Investment Advisers Act of 1940 that shape how the product was structured, disclosed, supervised, and operated.
The RIA was being structured as a distinct legal entity from the parent company, requiring appropriate regulatory and operational separation while coordinating with relevant functions across the broader organization.
Objective
The client’s objective was to register an affiliated entity with the US Securities and Exchange Commission as an investment adviser and prepare the RIA for commercial launch on an accelerated timeline. The immediate priority was to prepare and submit Form ADV to begin SEC review, while running compliance program development, product analysis, workflow design, and launch-readiness workstreams in parallel.
The engagement focused on building a compliance framework for an RIA operating inside a large, fast-moving fintech environment. This included SEC registration support, development of policies and procedures, books-and-records infrastructure, advertising review, communications monitoring, vendor management, personnel compliance, Code of Ethics requirements, complaint workflows, regulatory calendars, and preparation for SEC examinations from inception.
A key objective was to support the RIA’s integration with the parent company’s existing systems and enterprise compliance infrastructure while maintaining appropriate entity-level segregation. This separation was important for defining the RIA’s regulatory perimeter, documenting intercompany relationships, and limiting unnecessary regulatory exposure to the broader organization.
InnReg was also engaged to provide an outsourced Chief Compliance Officer for the RIA and ongoing compliance management following launch.
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Challenges
The client faced an accelerated timeline and a complex implementation environment. Registration, compliance program development, product review, and launch preparation was to progress in parallel, requiring coordination among multiple internal and external stakeholders.
The proposed RIA also required careful entity structuring. Because the adviser would have been affiliated with a large financial technology platform, the compliance program must have maintained clear separation between the RIA and the parent company. This required attention to governance, books and records, intercompany services, information barriers, vendor relationships, supervision, and documentation of which activities belong to the RIA versus the broader enterprise.
Cash management and investment-related functionality introduced additional regulatory considerations. The client’s broader platform already supports a range of financial and operational workflows for business customers. Building an RIA around investment-related offerings required analysis of how advisory activities will be presented, operated, documented, supervised, and integrated into user-facing and back-office systems.
The engagement also involved significant operational and technology coordination. The client expected high responsiveness, structured project management, clear deliverables, and cross-functional alignment with product and engineering teams. Compliance workflows needed to fit within existing systems, including tools used for customer support, product development, documentation, and internal execution.
InnReg's Solution
InnReg was supporting the client from registration planning through pre-launch compliance program development, with workstreams designed to move in parallel with the client’s accelerated product timeline.
SEC Registration:
Preparing the application for SEC registration, including Form ADV drafting, collection and assembly of required information, and coordination of regulatory communications. InnReg was also supporting strategy for addressing SEC follow-up requests and preparing written responses during the registration process.Compliance Program Development:
Developing the RIA compliance program in advance of commercial launch, including policies and procedures, regulatory books and records requirements, advertising review processes, communications monitoring, personnel compliance, Code of Ethics obligations, continuing education, vendor management, and annual compliance review planning.Outsourced Chief Compliance Officer:
Providing a qualified professional to serve as the RIA’s Chief Compliance Officer. The CCO role was structured to support day-to-day compliance management, regulatory oversight, review processes, escalation handling, documentation, and post-launch compliance obligations under the Investment Advisers Act of 1940.Product and Cash Management Review:
Reviewing the proposed investment-related offering, cash management use case, customer experience, product flows, revenue model, disclosures, and operating structure to identify compliance considerations before launch. This included coordinating with product and engineering stakeholders so regulatory requirements are reflected in the actual product and operational workflows, not just in written policies.Entity Separation and Enterprise Integration:
Advising on the integration of the RIA compliance program with the client’s broader enterprise compliance function while maintaining appropriate separation between the RIA and the parent company. This included attention to governance, intercompany relationships, documentation practices, books and records, information barriers, vendor arrangements, and regulatory exam readiness.Workflow and Systems Design:
Developing user-facing and back-office compliance workflows, including complaint intake and escalation procedures integrated with existing client systems. InnReg was also supporting the design of the compliance technology stack, including use of Regly for advertising review, vendor management, personnel compliance, policy management, audit trails, and recurring compliance task tracking.Ongoing Compliance Management Planning:
Building the framework for post-launch compliance operations, including annual Form ADV amendments, regulatory calendars, preparation for and management of SEC exams, responses to regulatory inquiries, advertising reviews, communications monitoring, vendor oversight, personnel compliance, books and records maintenance, and monitoring of regulatory developments.
Client Results
The engagement provided the client with a structured path to pursue SEC registration while preparing the affiliated RIA for launch. InnReg helped organize the registration process, prioritize Form ADV preparation, and coordinate parallel workstreams across legal, product, engineering, finance, partnerships, external counsel, and compliance stakeholders.
The compliance program was developed around the client’s specific operating environment: a large financial operations platform preparing to launch an affiliated RIA within a broader fintech enterprise. By addressing entity separation, intercompany relationships, books and records, governance, vendor oversight, and exam readiness early in the process, the framework helped define the RIA’s regulatory perimeter before launch.
InnReg’s role also connected compliance requirements to the actual product and cash management workflows. Rather than limiting engagement to registration paperwork, InnReg reviewed the product structure, customer-facing experience, internal processes, disclosures, and the technology needed to operate the RIA in practice.
With an outsourced CCO and support planned as part of the engagement, the client successfully built a compliance function for the new RIA while its internal teams continued to move quickly on launch execution.
How Can InnReg Help?
InnReg can help clients with the compliance requirements around a successful RIA launch. Whether it's regulatory exam readiness or personnel compliance, our team is ready to help. Reach out by filling the form below.
