The need for an adviser to have an effective compliance program cannot be overstated. In many SEC-settled enforcement proceedings, the only violation alleged is the adviser’s failure to comply with Rule 204(4)‑7 under the Investment Advisers Act of 1940, known as the “Compliance Rule.” To assist advisers in navigating their obligations under that rule, a recent ACA Group program addressed the fundamental elements of compliance programs; use of gap analysis and risk assessments to create an effective program; testing and documentation; and qualifications of CCOs and compliance staff. It featured Jaqueline Hummel and Myles Blechner, directors at ACA Group. This article synthesizes their insights. See our three-part series on tailoring a compliance program: “Why Fund Managers Should Customize” (Jul. 16, 2020); “What Fund Managers Should Consider” (Jul. 23, 2020); and “When Fund Managers Should Review and Update” (Jul. 30, 2020).