FINRA 3110 WSPs
FINRA Rule 3110 requires every broker-dealer member firm to run a supervisory system and to keep written supervisory procedures, usually called WSPs, that describe how the firm supervises each line of business and each associated person. The WSPs name the principals responsible, describe the reviews they perform, and say how those reviews are documented.
Related rules add an annual testing report (Rule 3120) and an annual CEO certification that the firm has processes to keep its procedures current (Rule 3130).
On paper, the firm needs the WSP manual itself, a record of supervisory personnel with titles, registrations, locations, and responsibilities, written reviews of investment banking and securities transactions, procedures for reviewing correspondence and internal communications, procedures for capturing and responding to customer complaints, and written inspection reports for offices.
Offices of supervisory jurisdiction and supervising branches are inspected at least annually; non-supervising branches at least every three years; other locations on a schedule the firm sets and justifies.
Who has to comply
All FINRA member broker-dealers and their associated persons. Applies regardless of firm size; small firms often adapt FINRA's WSP checklist.
What you have to write
Documents on this site that FINRA 3110 WSPs requires or expects, each with who must have it, the review cycle and the obligations that cite it.
- FINRA Written Supervisory Procedures Financial
What the assessor asks to see
Examiners typically ask for the current WSP manual and its change history, the list of supervisory personnel and delegation records, evidence of correspondence and electronic communication reviews, transaction review records, customer complaint logs and responses, branch and OSJ inspection reports with follow-up, the most recent Rule 3120 report, the Rule 3130 certification and supporting evidence, training records, and books and records showing retention under SEC Rule 17a-4.
Where the requirement sits: FINRA 3110(b) WSPs; 3110(a)(7) annual compliance meeting; 3120 supervisory controls and annual report; 3130 annual CEO certification; 4511 books and records
Every internal policy in one place
AllyMatter is a full system for every internal policy your company keeps, including the ones FINRA 3110 WSPs turns on. Build the whole library in one place, across every department, and prove who has read what.
Policies you can run here
How it works
Every document is approved by someone other than its author, versioned, distributed to the people it covers and acknowledged by name. Sign it where a signature is what the standard wants, send a set out together as a package, and export a dated record of who read which version when an assessor asks.
Most of what an assessor reads for this standard is written policy and proof that people acknowledged it. That is the layer AllyMatter owns.
Who helps with FINRA 3110 WSPs
A well developed ecosystem of broker-dealer compliance consultants, outsourced or fractional chief compliance officers, WSP template providers, and securities law firms.
Engagements typically involve rewriting or updating the WSP manual after a business change or exam finding, building the branch inspection program, and preparing the Rule 3120 report and 3130 certification package.
Firms that name this framework in their own material. A listing is not a recommendation. Each firm can confirm its own.
Consultants
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Who assesses FINRA 3110 WSPs
FINRA Member Supervision examiners conduct cycle and cause examinations; SEC Division of Examinations examiners also review supervision. There is no certification. FINRA is a self-regulatory organization registered with the SEC.
Assessors
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Tools for FINRA 3110 WSPs
Tools that name this framework in their own material.
Grouped by type. Inside each group the order is random, reshuffled each time the page loads. AllyMatter, the publisher of this site, is always first.
AllyMatterPolicy management tool, the policy and acknowledgment layerPublisher of this siteRelated reading
- Demystifying FINRA Rule 3110: A Comprehensive OverviewExplains who actually carries supervisory responsibility, what WSPs must specify, and how 3110 shows up in nearly every FINRA exam.Oyster Consulting
- Long-Awaited Guidance on New Rules Regarding Residential Supervisory Locations and Remote Branch Office InspectionsExplains Rules 3110.18 and 3110.19, the written procedures and risk assessment a firm needs before inspecting a location remotely.Sidley Austin
Independent third-party explainers, chosen by hand. Not affiliated with this site and not paid placements. All links are nofollow.
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From the publisher
Run the Policy Side of FINRA 3110 WSPs in AllyMatter
Approve the policies FINRA 3110 WSPs asks for, keep every version, and record a named acknowledgment from each person who has to read them.