The SEC has sanctioned and fined and investment adviser because it failed to implement an adequate compliance program as required by Rule 206(4)-7. One of the violations cited was using a template manual without tailoring it to the firm’s business. Pulling a manual off a website is not complying with the Rule. I can’t tell you how many manuals I read each year and when I ask if the firm does “x” or “y” in the manual, they didn’t even know it was in the manual.
I understand that investment advisers are busy. If you can’t manage your compliance program on your own – get help.