Docupace ComplianceEdge

Find Your Compliance Coverage GapBefore Your Examiner Does

Enter your own numbers, and in about two minutes, you’ll see how much of your book you could prove was reviewed, the ceiling your team’s hours can actually support, and the dollars sitting in accounts and trades nobody examined. Every figure comes from data you type in.

OCC Rule 9.6(c) Every discretionary fiduciary account, reviewed every calendar year
FINRA Rule 3110 THE PERIODIC REVIEWS YOUR WSPs PROMISE, EVIDENCED
Advisers Act Rule 206(4)-7 SEC examiners hold RIAs to their own written policy
Dually Registered Hold more than one? Every obligation applies

The Exam Moment

“Show me the documented review for this account.”Every exam gets here eventually.

The obligation

There is no partial credit

Whether the rulebook is the OCC’s annual investment review requirement, your FINRA Rule 3110 WSP cycle, or your own RIA compliance policy, a missed review is a finding. Examiners don’t grade on a curve. Ninety-four percent coverage is a gap, and the gap is what goes in the report.

The ceiling

Headcount sets a hard limit

Minutes per review, alerts per day, productive hours per analyst. Multiply it out and you get a hard ceiling on the coverage your team can deliver, whatever the policy promises. Most firms have never done that multiplication.

The accounts nobody reviewed and the trades nobody examined don’t show up on a report.
They show up in the exam.

The Calculator

What Your Coverage Actually Is, and What Closing the Gap Costs

One quick question about your firm, then three short steps. Ballpark figures are fine; every input stays editable and the results move as you change them.

First question

Which registrations does your firm hold?

Select every registration your firm holds. Your answer changes the obligation, the wording and the sources below. Any combination is fine — every obligation you select applies.

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Step 1 of 3 · Your book

What are you responsible for?

Four numbers size the obligation and the population at stake. Estimates are fine to start. Every result recalculates instantly, and you can jump back to any step from the bar above at any time.

Illustrative figures loaded. Replace them with your firm’s own data. The results are only as honest as the inputs.
accounts
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$
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$
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+ Fine-tune growth — defaults: 8% accounts, 12% trades
% / yr
% / yr
Stuck? Talk to Docupace

Step 2 of 3 · Current practice

What actually gets reviewed?

{{ fc.step2Intro }} {{ fc.rateNote }} Use your own observed rates — every exposure figure downstream is built on them.

reviews
Reviews you could produce evidence for, not reviews you believe happened.
%
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per year
Firm-wide total from your rules engine, not per account.
alerts
Reviewed, actioned and closed with a record. This is what coverage is measured on.
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Your own observed rate. Borrowed benchmarks invalidate the estimate.
+ Fine-tune timing — defaults: annual cycle, 30 min per item of work, 250 working days
days
365 annual, 90 quarterly, 30 monthly. Drives detection latency.
min
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min
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days
Stuck? Talk to Docupace

Step 3 of 3 · Your team

Who does the work?

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FTEs
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%
Above 50% is itself an exam talking point.
+ Fine-tune capacity & cost — defaults: 1,500 productive hrs, 55% on reviews, $85,000 loaded cost
hrs
Net of PTO, holidays, training and admin. Rarely 2,080.
%
The rest goes to exam prep, policy work, escalations, committee reporting.
mo
mo
$ / yr
Default $85,000 fully loaded, from the BLS median compliance-officer base of $78,420 (May 2024). Set it to your own market.
Stuck? Talk to Docupace

1 · Where coverage stands

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Capacity ceiling {{ r.achievable }}
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{{ fc.legendDone }} Ceiling your team’s hours can support {{ fc.legendMandate }}
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coverage achievable at current headcount and tooling
Reconcile this before your next exam. Your reported completions exceed your modeled capacity. Either reviews take less time than stated, the team is absorbing overflow outside normal hours, or review depth has quietly been reduced. An examiner will ask the same question.

2 · What’s likely sitting in the unexamined book — estimated

Two figures, each derived from a number you entered. Every one shows its arithmetic. No industry benchmark and no vendor claim sits anywhere in the chain.

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{{ fc.excDef }} Applying your own observed rate to a population you did not examine makes this an inference, not a measurement.

3 · The pressure ahead

Capacity utilization above 100% means the obligation cannot be met at current headcount. That is a ceiling, and money alone does not raise it quickly.

At your stated growth rates Year 1 Year 2 Year 3
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Capacity utilization{{ r.g1u }}{{ r.g2u }}{{ r.g3u }}
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of review work sits with two people. Above 50% is itself an exam talking point
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to replace one of them (recruit + time to competence)
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4 · Two routes to 100% coverage

Doing nothing isn’t acceptable, so there are two ways to close the gap: hire more {{ fc.staffMany }}, or raise throughput. Read the comparison below as cost avoidance against an obligation. It is not a savings claim.

+ Adjust the modeling assumptions behind the automation route
These describe what continuous, workflow-driven monitoring could change. You control every one of them. Set them to figures you would defend in a committee, or ask us to model them against your own telemetry.
%
%
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$ / yr
Enter a quoted price to see the full three-year comparison. Pricing depends on your book.
$

Hire to close the gap

Same coverage, reached by adding headcount
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Recurring annual cost
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Three-year cost
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Months before coverage improves
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Automate to close the gap

Same coverage, reached by raising throughput
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Recurring annual cost
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Three-year cost
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Months to production monitoring
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Based on a typical 14-week ComplianceEdge implementation to production monitoring. Your own scope sets the real figure.
Closing the coverage gap by hiring requires {{ r.hFtesLong }} at {{ r.hCostFull }} per year. Coverage doesn’t improve for {{ r.hMonths }} months while you recruit and train. Continuous monitoring reaches the same coverage in {{ r.aMonths }} months, which leaves the gap open {{ r.delayMonths }} fewer months.
Three-year cost of the hiring route above automation: {{ r.diff3yr }}
Enter a quoted subscription under “Adjust the modeling assumptions” to see the three-year cost comparison, or request a quote for your book below.
Both routes reach the same regulatory outcome. The counterfactual here is a requisition, not the status quo. Hiring costs are held flat for three years, which understates them.
At these inputs, your current headcount can reach full coverage. What’s left is the exposure sitting in the unexamined book and key-person concentration, in sections 2 and 3.

Keep these numbers

Download your results

Enter your work email and we’ll build a PDF of your coverage, exposure and hire-vs-automate figures, formatted for a compliance committee. We’ll follow up with how ComplianceEdge closes the gap.

It tells us whether to send you a plan or a point of view.

Your report opens as a PDF you can save or print. We use your details and inputs to follow up with relevant guidance — see our privacy policy.

✓ Your results are ready.

{{ gateThanks }} Your PDF just opened in a new tab. Use Print / Save as PDF to keep a copy. Bring these numbers to an exam-readiness conversation and we’ll model them against your real book.

Get your exam-readiness assessment

The Fix

What Continuous Supervisory Review Looks Like in Practice

ComplianceEdge runs fiduciary account review and trade surveillance as a continuous workflow instead of a year-end scramble. When an examiner asks to see a review, you export it.

A Rolling Review Cycle

Accounts come up for review on a rolling schedule, so exceptions surface in days. On an annual cycle the average issue sits roughly six months before anyone sees it.

Every Clear Is a Record

Low-risk accounts that auto-clear still produce a dated review record your examiners can verify. No analyst minutes spent on any of them.

Throughput Before Headcount

Workflow-driven triage cuts minutes per alert, so the team you already have covers more of the book. The ceiling moves without a 14-month recruiting cycle.

Evidence, Already Assembled

Every review, exception and escalation lands time-stamped in one audit trail. Assembling review documentation takes an afternoon rather than a project plan.

Questions

Account Review Requirements, Coverage and Staffing

What is OCC Rule 9.6(c)? +
OCC Rule 9.6(c) is the OCC rule requiring national banks and trust companies to review all assets of each discretionary fiduciary account at least once every calendar year. What examiners want is a dated record proving each review happened. Believing it happened does not count.
What does FINRA Rule 3110 require for account reviews? +
FINRA Rule 3110 requires broker-dealers to build periodic examination of customer accounts into their written supervisory procedures, to catch and prevent irregularities. Your WSPs set the cycle. Examiners then test whether those promised reviews can be evidenced. And where a firm agrees to monitor a retail account, Regulation Best Interest treats each agreed review as a recommendation in its own right.
How often must fiduciary accounts be reviewed? +
Banks and trust companies must review every discretionary fiduciary account every calendar year under OCC Rule 9.6(c). Broker-dealers follow whatever cycle their WSPs promise under FINRA Rule 3110. RIAs follow the cycle their own compliance program sets under Advisers Act Rule 206(4)-7, and SEC examiners hold the firm to that written policy.
What do examiners look for in annual account reviews? +
Evidence. A dated review record for every account in scope, matching what your WSPs or compliance policy promise. They also test the arithmetic. If your reported completions exceed what your team’s hours could plausibly support, expect a question about whether review depth was cut. The calculator above flags that contradiction first.
How many compliance analysts do I need? +
It depends on accounts in scope, minutes per review, alert volume and productive hours per analyst. No industry benchmark can answer it for you. The calculator above computes the coverage ceiling your current team can support, and the additional FTEs full coverage would require at your stated growth rates, from your own operating data.
Should we hire or automate to close a coverage gap? +
Both routes reach the same 100% obligation. Hiring adds capacity in roughly 12 to 18 months once you have recruited and trained a qualified analyst, and the gap stays open for all of it. Automation raises throughput per analyst and usually reaches production monitoring in weeks. The calculator compares the two on cost and months-to-coverage from your inputs.

See your coverage number, then
close the gap.

Bring your calculator results to an exam-readiness assessment. We’ll run your coverage, capacity ceiling and exposure against your real book, then show you what continuous, documented review looks like on it.

Methodology & Sources

Every headline figure derives from data you supplied. Exposure estimates take your observed exception rate on the examined population and apply it to the population you did not examine. That is an inference. Present it as one. The platform-effect figures (triage reduction, auto-clear share, surfacing cycle) are assumptions you set yourself, and none of them is a performance guarantee.

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This calculator produces planning estimates, not legal, regulatory, or accounting advice. Results depend entirely on the accuracy of your inputs. © 2026 Docupace Technologies. ComplianceEdge is a Docupace solution.