As your compliance consultant, Quadrant will provide your company with professional and cost effective alternatives to maintaining or developing an in-house compliance staff. Our professionals, consisting of former regulators and compliance officers, have extensive experience in both conducting and responding to sales practice and financial examinations of the SEC, FINRA, state regulators, and other SROs. Simply choose the level of service you want, continue to focus on and grow your business, and allow us to develop and guide your compliance program.
Table of Contents
- Supervisory Controls Test and Report
- Simulated Regulatory Examination
- Written Policies and Procedures
- Liaison with Regulators
- Annual Compliance Meeting
- Firm Element Continuing Education
- Registrations, Licensing, and Electronic Filings
- Disclosures and Attestations
- Training
- Business Continuity Preparation
- Branch Office Inspection
Supervisory Controls Test and Report
FINRA Rule 3120 requires Chief Compliance Officers or other designated principals of Broker-Dealers to annually prepare a report detailing the firm’s system of supervisory controls, a summary of test results, significant identified exceptions, and any additional or amended supervisory procedures created in response to the test results. FINRA Rule 3130 requires firms to prepare a written report describing the manner and frequency in which the processes of FINRA Rule 3120 are administered, as well as the identification of officers and supervisors who have responsibility for such administration. In addition, FINRA Rule 3130 requires the Chief Executive Officer to be provided the report in order to certify annually that the firm maintains a process to establish, maintain, review, test and modify written compliance and supervisory procedures. Quadrant will perform the reviews required to prepare both the FINRA Rule 3120 and FINRA Rule 3130 reports. In addition, Quadrant will prepare a draft of the CEO Certification. Prior to preparing the reports, we will conduct the following reviews:
- Identify your firm’s business activities and applicable rules, regulations, and internal controls for each activity;
- Identify your firm’s associated persons that have supervisory responsibilities and review the effectiveness of the firm’s supervision over these activities;
- Analyze and test your firm’s current supervisory procedures to determine if the procedures adequately address all applicable rules, regulations, and internal policies and controls; and
- Establish new or revise existing supervisory procedures where deficiencies are noted.
Simulated Regulatory Examination
Quadrant can perform a simulated regulatory examination that will help prepare you for your next FINRA or SEC examination. The simulated examination will allow your firm to formally identify, document, and prevent non-compliance in the future. Quadrant’s review is conducted in the same manner in which an examination would be performed by FINRA or the SEC. At the conclusion of the simulated examination, we will provide a confidential written report that includes a detailed summation of the reviews, findings, and recommendations to enhance your compliance program.
Written Policies and Procedures
There is no single compliance document more instrumental to a firm’s overall compliance program than Written Supervisory Procedures (WSPs). In accordance with FINRA and SEC requirements, regardless of a firm’s size, scope, or operational function, each firm must adopt and implement a supervisory system that is tailored specifically to its business. Our consultants can assist your firm with creating, periodically modifying, and implementing policies and procedures that address relevant activities of your firm and its associated persons. We have expertise in developing, customizing, and amending the following policies, procedures, and manuals:
- Written Supervisory Procedures
- Anti-Money Laundering Procedures
- Continuing Education Program
- Business Continuity Plan
Solving Compliance Challenges
Our experience as former regulators has not distorted our understanding of how business should be run in a financial marketplace but has given us the ability to know what regulators are looking for and the compliance challenges faced by our clients. We are dedicated to working with you to achieve compliance with the rules and regulations of all applicable regulatory bodies.
Liaison with Regulators
Quadrant is experienced in assisting firms with preparing for on-site regulatory examinations and can help you manage the entire examination process. In addition, we can assist with responding to regulatory inquiries. We will work closely with you to ensure that responses to regulators are adequate. Because we are former regulators, we have first-hand knowledge of what they are looking for in a response.
Annual Compliance Meeting
Quadrant can develop the agenda and training material that are applicable to your firm’s business risks for your ACM. In addition, we can assist with delivering and documenting the meeting.
Firm Element Continuing Education
Quadrant can help you determine which regulatory topics are most appropriate for your firm element continuing education requirements. The continuing education training program we develop will include the needs analysis of personnel, the specific topics that will be covered within the training, how the training will be delivered, and an assessment of the program to determine if the training was adequate.
Registrations, Licensing, and Electronic Filings
Quadrant is experienced with state registrations. Our expertise allows our clients to register in new states in an expeditious manner. In addition, we can serve as your FINRA Web CRD Administrator or support your firm’s designated Web CRD Administrator with the following:
- File electronic forms (Form BD, Form BR, Form U4, Form U5)
- Advise designated parties of relevant CRD requirements
- Perform the annual review of the FINRA Contact System
- Monitor Regulatory Element training requirements
- Perform the electronic filings required by MSRB
- Assist with examination scheduling, fingerprinting, and other CRD requirements
Disclosures and Attestations
Quadrant offers customized disclosure and attestation forms to notify your firm if any of its employees are participating in, or are subject to the following:
- Private securities transactions
- Outside business activities
- Outside brokerage accounts
- Disclosures or amendments to the Form U4
- Customer complaints and arbitration’s/litigation’s
Training
Quadrant can provide specialized training for your staff that adequately addresses all of your regulatory needs and concerns. Examples of our training include anti-money laundering, detecting and reporting customer grievances, communication reviews, new product implementation, supervision of firm personnel, and many others.
Business Continuity Preparation
Quadrant can assist you with developing an effective business continuity plan that will permit your firm to meet its financial and service obligations to customers and meet regulatory requirements. We can assist you with drafting both the business continuity plan and the notification that is required to be provided to your customers. Lastly, we can help you determine the best way to disseminate the notification to your customers.
Branch Office Inspection
FINRA Rule 3110 requires Broker-Dealers to conduct inspections of its branch office and non-branch office locations. The rule necessitates inspections for certain locations (Office of Supervisory Jurisdiction or OSJ) to occur on an annual basis. Quadrant can conduct branch office inspections that will assess the supervision and controls in place at your firm’s branch office locations. At the conclusion of the inspection, we will provide a report detailing the reviews conducted, findings, and recommendations to enhance your branch office compliance program.