Written Supervisory Procedures

What this video covers

• Why the supervisory system (the people, offices, and live processes) is not interchangeable with written supervisory procedures (WSPs), which are merely the documents describing that system
• How final supervisory responsibility always remains with the firm even when a registered principal like Sam is explicitly assigned to manage day-to-day supervision
• The three-and-two retention rule: preserve supervisory personnel records for at least three years total, with easy accessibility required for the first two years
• The two specific triggers that require prompt amendment of WSPs (regulatory or supervisory-system changes) and why promptly communicating those amendments to relevant associated persons is a separate, mandatory step
• Who must attend annual compliance discussions, who the firm may designate to conduct them, and why the content must be relevant to each participant's actual activities
• What the chief executive officer (CEO) or equivalent officer actually certifies each year (processes, not perfect compliance) and why this certification does not replace the firm's continuing duty to establish, maintain, and enforce its WSPs