Supervision is a critical component of an effective compliance program. Creating, implementing and maintaining a workable supervisory system can be a tremendous challenge, but the failure to have comprehensive policies and procedures tailored to your business, with well-defined responsibilities and authorities, or to effectively implement those procedures, can be disastrous for a firm.
A well designed supervisory system integrates effective oversight and control mechanisms into daily operating protocols without detracting from the firm's primary business objectives.
The lawyers in Proskauer's Broker-Dealer & Investment Management Regulation Group draw on decades of industry experience to offer practical supervisory solutions. We work closely with compliance personnel and management to identify the compliance challenges presented by each client's unique business model and to design or enhance supervisory systems compatible with the firm's culture and resources.
Below is a list of some of the topics we advise on in this area, as well as useful information and materials.
Compliance Audit and Certification (NASD Rule 3012; FINRA Rule 3130)
Gifts and Gratuities (FINRA Rule 3220)
Loans to Customers (FINRA Rule 3240)
Outside Business Activities of Associated Persons (FINRA Rule 3270)
Transactions by Associated Persons (NASD Rules 3040/3050)
Compliance Event Reporting (NASD Rule 3070)