
Daniel Padilla
Jan 5, 2026
Compliance structure must follow the business model—not the other way around.
While Registered Investment Advisers and Broker-Dealers operate in the same industry, they are governed by fundamentally different regulatory and operating models. Treating them as interchangeable—whether in compliance design, supervision, or operations—is one of the most common sources of friction, inefficiency, and regulatory risk we see.
Broker-Dealers are supervision-driven organizations. Their frameworks are built around transaction review, registered representative oversight, and layered supervisory approval. Policies, workflows, and documentation must support real-time supervision and clearly defined escalation paths. When Broker-Dealers borrow RIA-style flexibility or under-document supervision, gaps quickly emerge—often during exams.
RIAs, by contrast, are risk-based organizations. Effective RIA programs focus less on transaction-level supervision and more on fiduciary oversight, disclosure accuracy, and ongoing risk assessment. Over-engineering RIAs with Broker-Dealer controls often leads to unnecessary complexity, staff fatigue, and advisor frustration without meaningfully reducing risk.
The most effective firms recognize that compliance structure must follow business model. Governance frameworks, workflows, and technology should reflect how advice is delivered, how revenue is generated, and where real risk resides. When firms attempt to standardize across RIA and Broker-Dealer platforms without accounting for these differences, complexity compounds and accountability blurs.
At Ironwood Strategic Partners, we design programs with these distinctions in mind. Rather than forcing one framework to fit both models, we help firms build right-sized structures that align with regulatory expectations and operational reality. The result is infrastructure that is clearer, more efficient, and far better positioned to withstand scrutiny—without slowing the business down.