COMPLIANCE
The five duties, the whole book, one screen.
Loyalty, prudence, plan documents, diversification, reasonable expenses. Each obligation sits under the duty it answers to, and one square per plan shows where the proof is thin.
A spreadsheet, the TPA's word, and a file nobody can find.
The spreadsheet
knows what is due. It does not know what proves it was done.
The TPA's word
the 5500 was filed. The acknowledgment is in somebody's sent items.
The file
the signed 408(b)(2) exists, in a folder named for the quarter it was signed.
Filed under the duty it answers to.
| Duty | What sits under it |
|---|---|
| Loyalty | the sponsor contract, late deposits, education sessions, beneficiary designations, the ERISA bond |
| Prudence | the investment review, the committee meeting, the IPS review |
| Plan documents | ADP/ACP testing, the summary annual report, Form 5500, the safe harbor notice, 8955-SSA, the SPD |
| Diversification | the QDIA notice |
| Reasonable expenses | the 404(a)(5) notice, the 408(b)(2) disclosure, the management agreement |
One duty per obligation. A ring reads the proof on file under its duty, not a count of items.
One square per plan.
Grouped by advisor, by recordkeeper or by plan year end. Coloured by what is late, by what is due in 30 days, or by exam readiness.
Current by a date.
Current means nothing late and nothing done without evidence. Work due inside the window is on track, not backlog. The date comes from the picks engine run forward a working day at a time, with each obligation's own calendar adding what falls due, the same caps as the daily lists, and one line per person. On a small book the paces tie and the card says so. On a four-hundred-plan book they separate by months.
Other people's items, counted apart.
The sponsor's, the TPA's and the recordkeeper's items are on the same calendar with their owner named, and they never set a plan's headline. The firm's own items carry the cite each one answers to.
An item owed by the TPA opens on Today with the draft to them already in your Outlook.
The firm's own twenty-three, with the rule each answers to.
| Obligation | Rule | Cadence |
|---|---|---|
| Form ADV annual updating amendment | Rule 204-1 | each year |
| ADV Part 2A delivery or offer to clients | Rule 204-3 | each year |
| Annual compliance program review | Rule 206(4)-7 | each year |
| Access-person quarterly transaction reports | Rule 204A-1 | each quarter |
| Vendor due-diligence refresh | Reg S-P | each year |
| Incident response program | Reg S-P 248.30 | continuous |
| Cybersecurity risk assessment | Reg S-P | each year |
| User-access review | Reg S-P | each quarter |
| Identity theft red flags program review | Reg S-ID | each year |
| PTE 2020-02 retrospective review | PTE 2020-02 | each year |
| ERISA 408(b)(2) fee disclosures | ERISA 408(b)(2) | continuous |
| Best-execution review | Sec. 206 | each year |
| Form CRS amendments and client delivery | Rule 17a-14 | continuous |
| Advertisement substantiation before use | Rule 206(4)-1 | each time it is used |
and nine more, with their dates
These are the firm's own rows. The cite is on the row so a reviewer can check it.
Print the exam file.
One plan or the firm, black on white, a page per duty: what is owed, what proves it, and what is missing. A page with nothing on file prints the one line that says so.
| Statement in force | Signed Jan 29, 2026 |
| Quarterly investment review, Q2 2026 | Acknowledged |
| Quarterly investment review, Q3 2026 | DRAFT |
| Committee meeting | Held Jun 11, 2026 |
| Committee minutes, Q3 2026 | MISSING |
A book of four hundred plans, on one screen.
The squares shrink to fit, with the late count inside down to 22 px. Groups open one at a time with the ten most late shown. The first paint on a 424-plan test book is under half a second.
Questions a compliance lead asks.
Where do the obligations come from?
The firm's own catalog, 45 kinds, each with its cadence, its owner and the rule it answers to.
What happens when a plan does not owe one?
It is waived with a reason on the row, and it stops counting.
What counts as proof?
A document on the obligation, or a dated record of the call or meeting that closed it. Done with nothing on file reads "recorded, no document".
Can the assistant close an obligation?
Only by filing the document that proves it. Anything else comes back as a question for a person.