Written Supervisory Procedures and Controls: Rapid Fire

What this video covers

• Why the seven pillars of a supervisory system must all be present, and how the reasonable-review standard scales procedures to firm size and risk
• The fatal trap that perfect written supervisory procedures (WSPs) on paper still fail if they are never tested through internal supervisory controls
• How office classification drives inspection frequency: OSJs and supervising branches annually, non-supervising branches, non-branch locations, and residential supervisory locations (RSLs) at least every three years
• The absolute prohibition on self-inspection and the forced on-site visit rule when red flags surface during remote inspections
• Why the internal supervisory controls report and the chief executive officer (CEO) certification report are different documents with different audiences, and why the CEO signature cannot be delegated to the chief compliance officer (CCO)
• The exact sequence of CEO certification on the rolling anniversary date, then the 45-day board report deadline, and the $200 million gross revenue trigger for enhanced controls reports
• Why omitting customers' prompt access to funds and securities makes a business continuity plan (BCP) presumptively non-compliant, and how emergency contact persons (ECPs) differ from Form U4 filings