It is not technically required under the Advisers Act (the compliance program rule applies to RIAs, not ERAs). But as a practical matter, yes.
Institutional LPs expect it during due diligence. A compliance manual documents your firm's policies and protects you by establishing standards of conduct. It also makes a future transition to RIA registration much smoother. Build one early, review it annually, and follow it.
This article is for informational purposes only and does not constitute legal advice. Consult qualified professionals for guidance specific to your situation.