Supervisory Review of Representative Correspondence and Activity

What this video covers

• The three buckets of required review: incoming client correspondence, outgoing client correspondence, and internal communications related to the firm's investment banking or securities business
• How the "appropriate for the firm's business, size, structure, and customers" standard applies specifically to correspondence-review procedures, not just general written supervisory procedures
• Why a registered principal may delegate the task of reading correspondence to unregistered personnel but can never delegate the ultimate supervisory duty or responsibility
• What a reasonably designed, risk-based review system requires when every message is not reviewed before use: education and training, documented training, and surveillance with follow-up
• The four categories that trigger mandatory review every time: customer complaints, customer instructions, customer funds and securities, and anything federally mandated
• Why merely opening or accessing a communication fails the review standard, and what three items the written record must always contain: reviewer name, item reviewed, and date of review
• When the fourth documentation item, action taken, is actually required: only when the review identifies a significant regulatory issue, making it conditional rather than universal