Phase One:  October 5, 2004 Final Rule 38a-1 gave separate accounts, underlying funds and investment advisers until October 5th to adopt, and obtain depositor/board approval of, comprehensive written compliance policies and procedures for the RIC and its service providers, and to hire a chief compliance officer ("CCO"). 

Phase Two:   No later than April 5, 2006 financial services organizations must have completed the first annual review of the adequacy and effectiveness of the compliance policies and procedures of the RIC and each of its service providers.

Phase Three:  Within 60 calendar days of completion of annual review (no later than June 4, 2006), the CCO must submit the first annual report to the board/depositor of each RIC.  The annual report must address the results of the review of the operation of the policies and procedures of the RIC and its service providers, any material changes that were made or recommended, and any "material compliance matters."