Effective written supervisory policies, procedures, and internal controls (WSPs) should be structured and implemented to help prevent abuses, detect and mitigate conflicts of interest, reduce firm risk, and maintain legal compliance with protocols and regulatory requirements.
Based on our comprehensive experience with broker-dealers, we are able to assist broker-dealers in developing and implementing WSPs. Our approach is to work with management to define the roles and responsibilities of your senior management and supervisors, while promoting successful business practices. To help accomplish this, our ongoing consultation may include advice and guidance regarding:
- Creation, review, enhancement or implementation of WSPs
- Guidance on constructing a “Chinese Wall,” supervising interdepartmental communications communicating Restricted and Watch Lists
- Employee training on new policies and procedures
- Development of Business Continuity Plan pocuments
- Development of Anti-Money Laundering Policies and Procedures, including an annual independent audit
- Analysis of Best Execution practices and review of Best Execution processes and compliance with SEC and FINRA recordkeeping requirements
- Evaluation and implementation of recordkeeping and document retention policies
- Review and assessment of Privacy Policies and Procedures regarding safeguards for protecting confidential client information
- Analysis of the conflicts of interest processes
- Annual Testing of the policies, procedures and internal controls, including a written assessment of same