POLICIES organizes, manages and delivers your firms policies and WSPs. POLICIES provides a clean, easy-to-use, easy-to-search and up-to-date experience for your advisors. POLICIES brings all of your procedures, policies, WSPs and other documentation into one place that can be accessed on both desktop and mobile devices.
POLICIES ensures compliance with FINRA rules 3110, 3120 and 3130 by making sure the most up-to-date policies and WSPs are accessed and utilized by your advisors. Our search and tag technology allow your advisors to quickly find the information they need to stay compliant, limiting calls and emails to compliance for support.
FINRA Rule 3110. Supervision
FINRA 3110 rule requires a firm to have “reasonably designed” Written Supervisory Procedures (WSPs) to supervise the activities of its associated persons.
OurPoliciesApp will allow you to document and track your WSPs and ensure that your registered advisors always access your current policies. Our intelligent searches provide clean and simple results for quick and accurate reference of your WSPs.
Section 7: “A copy of a member's written supervisory procedures, or the relevant portions thereof, shall be kept and maintained in each OSJ and at each location where supervisory activities are conducted on behalf of the member. Each member shall promptly amend its written supervisory procedures to reflect changes in applicable securities laws or regulations, including FINRA rules, and as changes occur in its supervisory system. Each member is responsible for promptly communicating its written supervisory procedures and amendments to all associated persons to whom such written supervisory procedures and amendments are relevant based on their activities and responsibilities.”
Our Policies app is a cloud-based program allowing a copy of your WSPs to be accessible by all. Our support team will promptly make any changes you request, ensuring seamless formatting and approval before publishing any of your WSPs. With responsibility falling on the supervisors to communicate all amendments to all “associated persons”, utilizing our Policies app will help ensure that your advisors are always referencing the most current publication.
FINRA Rule 3120 requires a firm to have a system of supervisory control policies and procedures (SCPs) that tests and verifies a firm's supervisory procedures. These policies and procedures need to be “readily accessible” by their registered advisors.
With your SCPs documented within our Policies App you will be able ensure that your registered advisors always have “readily accessible” your most current policies. Our intelligent searches of your policies within our app allows your registered advisors to quickly find the policies they need to reference.
FINRA Rule 3130. Annual Certification of Compliance and Supervisory Processes
FINRA Rule 3130requires the firm's chief executive officer(s) (CEO(s)) to certify annually that the firm has processes in place to establish, maintain, review, test and modify policies and procedures reasonably designed to achieve compliance with applicable securities laws and regulations and FINRA rules.
With ease, our Policies App will allow you to maintain, review and modify policies and procedures and provide the documentation you need to establish compliance.
FINRA Rule 3270. Outside Business Activities of Registered Persons
FINRA Rule 3270 requires broker dealers to review in advance the Outside Business Activity of registered advisors. Registered advisors “should” be getting pre-approval and “should” be giving full disclosure. When what “should” be disclosed is not. How do you protect your firm?
Eagle Eye will identify online activity associated with registered advisors. This app will also discover other DBA’s associated with your registered advisors. (Undisclosed DBAs are a growing concern for FINRA according to their annual Report on Examination Findings)
5% of Eagle Eye findings are undisclosed OBAs and DBAs.
One supervisor client shared with us, “Since implementing Eagle Eye our registered reps now come to us immediately if they have an OBA or DBA that we need to approve. They are no longer waiting for a once a year report.”