Once an adviser has established a compliance program with appropriate policies and procedures, it must implement that program effectively. An ACA Group presentation that is part of its ongoing “Building a Gold Standard Compliance Program” focused on two important elements of program implementation: compliance calendars and compliance testing. The program, which featured ACA Group’s Cari Hopfensperger, director, and Jaqueline Hummel, director of thought leadership, explored the importance of creating a compliance calendar; assigning responsibility for compliance; identifying common test areas; using available information for testing; incorporating testing into the annual compliance review; and embedding compliance throughout an organization. This article summarizes the relevant takeaways for closed-end fund managers. See our three-part series on tailoring a compliance program: “Why Fund Managers Should Customize” (Aug. 24, 2021); “What Fund Managers Should Consider” (Aug. 31, 2021); and “When Fund Managers Should Review and Update” (Sep. 14, 2021).