As part of the new Supervisory Controls Procedures, FINRA Rule 3013 requires “each member firm’s chief executive officer (CEO) to certify annually that senior executive management has in place processes to: (1) establish, maintain, and review policies and procedures reasonably designed to achieve compliance with applicable FINRA rules, Municipal Securities Rulemaking Board (MSRB) rules, and federal securities laws and regulations; (2) modify such policies and procedures as business, regulatory, and legislative changes and events dictate; and (3) test the effectiveness of such policies and procedures on a periodic basis, the timing of which is reasonably designed to ensure continuing compliance with FINRA rules, MSRB rules, and federal securities laws and regulations.”[1]

1st BridgeHouse can conduct an independent review and test of your compliance systems and procedures and provide your firm with written recommendations on suggested changes, all designed to comply with Rules 3010, 3012, and 3013. This assessment will involve a detailed analysis of your Written Supervisory Procedures (WSP) and AML procedures, as well as an onsite visit to evaluate how the firm’s systems comply with the various rules and the WSP. When the examination is completed and recommended changes have been implemented, you will have an independent review and test that will give the CEO the confidence to make the above certification.

[1] FINRA Notice to Members 04-71