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Who decides at asset managers and RIAs: operations signs, compliance and vendor risk block. What DORA, FCA SYSC 8 and SEC rules mean for vendors.
By Moe Alhosni · Published 29 October 2026 · 9 min read
Short answer: At an asset manager, the investment side usually wants your product and the operations side decides whether it gets bought. The COO or head of operations often signs. Compliance, operational due diligence, information security and legal can each block. At a small RIA, one or two partners decide, and the chief compliance officer is the gate. Sell to the user, but build the case for the people who run the firm.
I covered asset managers for most of my 4 years and 7 months at Moody's in London (October 2019 to April 2024): first as an Account Manager on Tier 1 banks and asset managers, then in Credit Solutions sales covering asset managers, and finally as Assistant Director, Sales, covering central banks, financial institutions, asset managers, PE and VC across Central and Eastern Europe plus Portugal, Malta and Cyprus. This article is the general version of what that taught me about how investment firms buy. It contains no former employer's data, methods or client names.
It is a B2B guide: for firms selling software, data or services to asset managers, RIAs and wealth managers. If you are an asset manager trying to raise money from investors, that is a different problem with different rules. See when a cold email becomes a financial promotion and FINRA 2210 and the SEC Marketing Rule for prospecting emails.
"Asset manager" covers a global fund house with thousands of staff and a three-partner RIA. They buy very differently.
| Large asset manager | Small RIA or boutique | |
|---|---|---|
| Who wants it | A portfolio team, research, risk, or data | A partner or the head of investments |
| Who signs | COO, CTO or head of a function, within a budget | A managing partner |
| Main gate | Procurement, vendor risk, information security, legal | The chief compliance officer, often part-time or outsourced |
| What slows it | Committee reviews and budget cycles | Bandwidth: nobody has time to evaluate you |
| What speeds it | A sponsor with budget and a complete vendor file | A short trial and a clear answer to "what does compliance need?" |
The mistake I saw most was selling to the second column with the first column's process, or the other way round. A small RIA does not want a 40-page security deck. A large manager will not buy on a handshake.
| Role | What they care about | Signs? | Blocks? |
|---|---|---|---|
| Portfolio managers and analysts | Better decisions, saved time, an edge | No | Rarely; they lose interest |
| CIO or head of an investment team | Performance, team productivity | Sometimes, for their own budget | Yes |
| Head of data or market data | Licensing terms, overlap with feeds they already pay for, usage rights | Often controls the data budget | Yes, on overlap and licensing |
| COO or head of operations | Cost, operational risk, how many systems they run | Often | Yes |
| CTO or IT | Integration, support, security | Sometimes | Yes |
| Procurement | Price, terms, competition | Runs the process | Yes, on process |
| Vendor risk or operational due diligence | Your risk rating and evidence | No | Yes |
| Compliance | Regulatory exposure, records, marketing use of your output | No | Yes |
| Legal | Licence terms, liability, data protection | No | Yes |
Two things stand out from that table. First, the user and the signer are different people. The portfolio manager who loves your tool in a demo does not hold the budget, and usually will not fight for it past one email. Second, market data has its own politics. If your product is data, expect the head of data to ask what you replace, because they are paid to keep the data bill under control. Have an answer about overlap before they ask.
Asset managers are regulated on how they rely on suppliers, as banks are, though the rules differ.
This is general information, not legal advice; check with your compliance team or counsel.
In practice, that means a vendor review that asks for your security posture, business continuity plans, subcontractors, data location, incident handling and exit arrangements. If your product touches client data or anything that feeds an investment decision, the review gets deeper.
At a small RIA, the chief compliance officer is often the real gate, and they are usually short of time. Make their job easy:
A few patterns I saw repeatedly, stated generally:
Start with the person who feels the problem, then add the person who controls the budget.
Write about their problem in their words. "We help asset managers with data" is noise. A specific process that takes a named team a day every month, and how you remove it, is a reason to reply. Then follow up patiently; investment firms are multi-person decisions, and the reply often comes from a colleague. The sequence design is in how many follow-ups a cold email sequence needs.
Selling to an asset manager is ordinary B2B marketing. In the UK, the financial promotion restriction in FSMA section 21 covers communicating "an invitation or inducement to engage in investment activity", and selling software to a fund house is not that. The email rules still apply, and they vary by country: the full breakdown is in is cold email legal for financial services.
We book meetings with the people above at the firms you choose, and charge per qualified meeting that took place. The honest position on proof: ROI Maximizer has not run a finance campaign yet. Our published results are in PR, not finance. PR Noir got 27 leads, 10 qualified meetings and a $90K deal, and P1 Communications, a hospitality PR agency, got 20+ qualified meetings. For asset managers, what I bring is knowing who signs and who blocks.
Prices: a setup fee of $1,000–$3,000, then $200–$500 per qualified meeting that took place, or a flat $5,000 a month. No minimum term, and nothing for a no-show. The segment page is lead generation for asset and wealth management, and the wider offer is on the financial services page. If you also sell to banks, the bank version of this map is how to sell to banks.
At a larger firm, the user is usually on the investment side, while the COO, head of operations, head of data or CTO holds the budget and signs. Procurement, vendor risk, information security, compliance and legal review the purchase and can block it. At a small RIA, a managing partner decides and the chief compliance officer is the main gate.
Go to a managing partner with a specific problem, offer a short trial, and give the chief compliance officer what they need in one page: what data you touch, what records you create, your security summary and your incident process. RIAs must keep written compliance policies under Rule 206(4)-7, so compliance will ask.
Not when you are selling a B2B product or service to them. Under FSMA section 21, a financial promotion is an invitation or inducement to engage in investment activity. The finance-specific rules apply when an investment firm emails to promote its own funds or advisory services. Email laws such as PECR in the UK, CAN-SPAM in the US and CASL in Canada still apply to everyone.
Yes, in different ways. EU fund managers fall under DORA for ICT services, UK firms under the FCA's SYSC 8 outsourcing rules, and US advisers under their written compliance programme and Regulation S-P. Expect a vendor review scaled to how important your service is.
If you hire anyone to book meetings with investment firms, us included, get three things in writing first.
Then put your contract value and close rate into the ROI calculator to see what a meeting with an asset manager is worth to you.
If you sell to asset managers or RIAs and want to talk through who to target, book 30 minutes or email moe@roimaxi.com.
Moe Alhosni, founder, ROI Maximizer (M Ventures LTD, 4 Beau Street, Bath BA1 1QY).
About the author: Moe Alhosni, founder of ROI Maximizer. Before that he spent four and a half years in sales at Moody's in London, most recently as Assistant Director, Sales, working with banks, asset managers and private equity firms. He runs the campaigns behind the first-hand data on this site. LinkedIn
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