Broker-Dealer Supervision and Control: Rapid Fire
Chapters in this video
- 0:00 The supervisory system vs. written supervisory procedures (WSPs)
- 0:56 Three segregation of duties prohibitions and the documented exception
- 1:38 Four controls: barriers, access, entitlements, and restrictions
- 2:41 Establishing WSPs vs. testing them, plus prompt amend-and-communicate
- 3:36 Annual CEO certification: process, not perfection
- 4:02 The five numbers: retention, accessibility, compliance talks, emergency contacts
- 5:57 Business continuity plan disclosures and the single principal approval
- 7:01 Rapid-fire exam recap
What this video covers
- How the supervisory system differs from the written supervisory procedures (WSPs), and why final responsibility stays with the firm regardless of how the manual is written
- The three specific prohibitions under segregation of duties, and the documented exception when firm size or specialized position makes separation impossible
- The four distinct controls: information barriers, access controls, entitlement policies, and information-access restrictions, and which question each answers
- Why establishing WSPs and testing WSPs are separate functions performed by different parties
- The prompt amendment and prompt communication requirement when the law or the supervisory system changes, and why updating the document alone fails
- What the annual chief executive officer (CEO) certification covers: processes to establish, maintain, review, test, and modify WSPs, not perfect compliance
- The three retention and frequency numbers: supervisory-personnel records kept at least three years with the first two easily accessible, annual compliance discussions for each registered representative and registered principal, and two emergency contacts to the Financial Industry Regulatory Authority (FINRA) with at least one senior-management registered principal
- The written business continuity plan (BCP) requirements: disclosure at account opening, on the website, and by mail on request, plus approval and review by one senior-management registered principal
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