Broker-Dealer Agent Supervision: Rapid Fire
Chapters in this video
- 0:00 WSPs: the firm's only shield against supervision failures
- 2:05 CEO annual certification and the five-step process
- 3:38 Three office tiers and their risk profiles
- 4:28 OSJ annual inspection vs branch office 3-year cycle
- 5:12 Trap: branch supervising non-branch goes annual
- 6:07 Failure to reasonably supervise as standalone violation
- 7:04 Three-part good faith defense and the paper-only trap
- 7:54 Rapid-fire exam recap
What this video covers
- What written supervisory procedures (WSPs) must include: who reviews what, how often, and how review is documented
- Why final responsibility for supervision rests with the firm, not with any delegated individual supervisor
- The five elements the chief executive officer (CEO) certifies annually and the required chief compliance officer (CCO) meeting within the prior 12 months
- How the three office tiers differ: Office of Supervisory Jurisdiction (OSJ), branch office, and non-branch location
- The inspection cycle for each tier: OSJs annually, standard branch offices at least every 3 years, and the trap that a branch supervising a non-branch location moves to annual
- Why failure to reasonably supervise is a standalone violation that reaches partners, officers, and directors, alongside the required public-interest finding
- The three-part good faith defense and why having WSPs on paper without reasonable enforcement collapses the defense
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