We are well equipped to assist broker-dealers in taking proactive steps required to identify, assess and reduce areas of risk. A significant aspect of the risk assessment process includes regulatory testing pursuant to FINRA Rule 3120, and on-site mock regulatory testing of client systems and BD procedures. This independant testing process is an important and integral part of the risk management and regulatory process broker-dealers should incorporate as a part of their addressing their annual testing requirement. As part of the testing and risk assessment process, we evaluate the aspects of your business subject to regulatory compliance, including:
- Bookkeeping records
- Account ledgers
- Trading and transaction records
- New account documentation
- Customer complaints and arbitration matters
- Associated persons’ and representatives’ files
- Advertising and marketing materials
- Written policies and procedures manuals
- Firm registration records
- Client disclosure documents and Privacy Notices
- Testing of Anti-Money Laundering Programs, Business Continuity Plans, Regulation S-P Controls and Other Compliance Programs
- Client Contracts and Account Files
- Processes for evaluating actual and potential conflicts of interest and the ultimate mitigation of those conflicts
- New products and services, including processes for business development and creation and implementation of new policies and procedures
Upon completion of the Firm’s testing or risk assessment, you will be provided with an initial finding report, which will address any critical concerns requiring immediate action. Additionally, based upon your needs, we are also to issue a final report that addresses the annual report occasioned by FINRA Rule 3120.