---
title: "Build a gap list for an adviser's written compliance program"
url: "https://ailawframework.com/practice/financial-services-regulation/draft-an-ai-risk-register-for-a-fund-manager/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A28-B8-3-US"
practice_area: "Financial Services Regulation (AFSL/ASIC/credit)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build a gap list for an adviser's written compliance program

> Compare the adviser's written policies with three questions: whether they are reasonably designed to prevent violations of the Advisers Act and the Commission's rules, whether a review at least annually is described,…

Canonical page: https://ailawframework.com/practice/financial-services-regulation/draft-an-ai-risk-register-for-a-fund-manager/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Financial Services Regulation (AFSL/ASIC/credit)](https://ailawframework.com/practice/financial-services-regulation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Compare the adviser's written policies with three questions: whether they are reasonably designed to prevent violations of the Advisers Act and the Commission's rules, whether a review at least annually is described, and whether a chief compliance officer is named. Quote no policy into a new manual. |
| What the lawyer must review | 17 C.F.R. § 275.206(4)-7 requires an adviser to adopt and implement written policies and procedures reasonably designed to prevent violation of the Act and the rules, to review at least annually the adequacy of those policies and the effectiveness of their implementation, and to designate a supervised person as chief compliance officer. SEC press release 2024-36 describes charges against two investment advisers for AI-related misstatements. A gap list is not the policy. You write any policy that will be adopted. Opinion 512 and Rule 1.6 apply if client or firm records go into the tool. |
| Written for | United States |
| Applies to | [Draft an AI risk register for a fund manager](https://ailawframework.com/practice/financial-services-regulation/draft-an-ai-risk-register-for-a-fund-manager.md) |

## Checking plan

- What the AI does: Compare the adviser's written policies with three questions: whether they are reasonably designed to prevent violations of the Advisers Act and the Commission's rules, whether a review at least annually is described, and whether a chief compliance officer is named. Quote no policy into a new manual.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The Marketing Rule text was not opened. Do not add a subsection number for it.
- The gap list is not signed and is not filed.

## Sources

- [17 C.F.R. § 275.206(4)-7, compliance procedures and practices](https://www.law.cornell.edu/cfr/text/17/275.206(4)-7) (checked 2026-10-22)
- [SEC press release 2024-36, charges against two investment advisers for AI-related misstatements](https://www.sec.gov/newsroom/press-releases/2024-36) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*