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Written
Supervisory Procedures
Written Procedures
(Model)
Our Model Procedures Manuals are continually
analyzed and updated as a result of regulatory
reviews and changes in industry practices and
technology. As a result of our frequent
interaction with the SEC, NASD and state
regulatory bodies, SCA’s procedures cover the
latest regulatory initiatives.
Our model procedures include specific manuals for
each of the following:
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Written Supervisory
Policies and
Procedures
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Written Supervisory Control Policies
and Procedures (NASD Rule 3012 and
3013) |
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Policies and Procedures for Registered
Representatives |
Our model
procedures are designed to provide guidance to
firms who are developing new procedures or
modifying existing procedures. Firms should not
adopt “off the shelf” procedures without
substantial modifications to conform to the
firm’s business activities and operations.
Written Procedures
(Customized)
SCA staff will customize the Model
Policies and
Procedures to meet the
specific needs of each client.
We can also review and update your current
supervisory and compliance procedures.
Regulator Expectations
NASD
Rules 3012 and 3013, along with amended NASD Rule
3010, set forth the current requirements for a
supervisory system.
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Rule 3013 requires the CEO to certify that the
firm has a process to adopt adequate Supervisory
Policies and Procedures
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Rule 3010 requires the establishment
of a supervisory system and
implementation of adequate written
supervisory policies and procedures |
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Rule 3012 requires each firm to test
and verify supervisory procedures
and, if necessary, to amend policies
and procedures |
Minimum Requirements for a Supervisory System and
Procedures are discussed in
NTM 99-45. These requirements include:
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Written Supervisory Procedures reasonably
designed to achieve compliance with all
applicable laws and regulations |
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Designating
Qualifications of Principals
Responsible for Supervision |
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Designating
Offices of Supervisory Jurisdiction |
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Annual
Compliance Meeting |
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Review of
Supervisory Procedures on a regular
basis |
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Annual
Inspection |
More detail on NASD expectations regarding
supervisory procedures is found in the NASD
Written Supervisory Procedures Review Checklist. Although this list is not to be considered a “safe
harbor” or all inclusive, guidance is provided on
what areas NASD examiners are currently reviewing.
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