Compliance Consulting
Our Services, Our Clients, Our Approach
Our Compliance Division Services
SDDCO is pleased to provide wide-ranging compliance guidance and solutions for your company:
- Registrations & Licensing
- Disclosures & Certifications
- Policies & Procedures
- Supervisory Controls
- CEO Certification
- Independent Review (Mock Audit)
- Annual Compliance Meeting
- Annual Review of Business Operations
- Continuing Education
- FINRA New Member Application
- FINRA Continuing Membership Application
- AML Effectiveness Testing
- Business Continuity Planning
Registrations and Licensing
SDDCO can serve as your FINRA Web CRD Administrator or assist your firm’s designated Web CRD Administrator to accomplish the following:
- Determine Content and File electronic forms
- Advise designated parties of relevant CRD requirements
- Perform the required quarterly review of FINRA Contact System
- Monitor Regulatory Element Training requirements
- Facilitate examination scheduling, fingerprint cards, and other CRD administrative requirements
- Assist with Blue Sky filings
Disclosures & Certifications
SDDCO can provide customized attestation and disclosure forms and work with your registered representatives to disclose the following:
- Outside Accounts & Personal Trading
- Outside Business Activities
- Private Securities Transactions
- Foreign Financial Accounts
- Form U4 Information
- Pre-Dispute Arbitration
Policies & Procedures
FINRA and the SEC require that policies and procedures are implemented within your company to help you accomplish your ongoing compliance with all applicable rules, which include FINRA, SEC, SIPC, and state rules relevant to your securities business.
Our on-site consultants can expertly support the foundation and documentation of internal policies and procedures--the keystone of effective compliance. We can be relied upon to create, modify, and implement relevant policies to cover each aspect of your business on a continuous basis. Through close contact with your supervisory staff, we can steer the development, customization, and amendment of the following policies, procedures, and manuals:
- Written Supervisory Procedures
- Anti-Money Laundering Procedures
- Continuing Education Program
- Business Continuity Plan
Return to List of Compliance Services
Supervisory Controls
Broker/Dealers are expected to establish procedures whereby they test and verify their compliance with all applicable rules. Monitoring or supervising your internal procedures can be a complicated business.
- SDDCO can pilot your compliance with FINRA's NASD Rule 3012 regarding Supervisory Control Systems
- Inventory all products or businesses
- Identify all supervisors
- Analyze the applicable industry rules and regulations
- Investigate your firm’s specific internal control requirements
- Identify gaps between industry laws and your existing supervisory procedures
- Review the compliance steps and timetables expected of supervisors
- Suggest updating your procedures or adopting a new supervisory process
CEO Certification
Your Chief Compliance Officer (CCO) is expected to meet with your CEO at least once annually and to verify by written report that the firm has systems in place to institute, maintain, test, and modify your written compliance policies and supervisory procedures.
-
SDDCO can prepare a draft of your CEO Certification Report in accordance with FINRA's NASD Rule 3013
Independent Review (Mock Audit)
To prepare for your next FINRA examination or to formally identify, document, and prevent future compliance omissions and complications, SDDCO can perform, on a project basis, an in-depth, independent review of your existing policies and procedures.
- The SDDCO Supervisory & Operational Independent Review is followed up by a confidential written report prepared for management that includes our consultant’s suggestions and detailed summation.
Return to List of Compliance Services
Annual Compliance Meeting
SDDCO can develop the relevant content for your annual compliance meeting and help your CCO deliver and document the meeting on-site.
Annual Review of Business Operations
SDDCO can examine aspects of your business operations and prepare your Annual Business Operations Report per FINRA Rule 3010(c).
Continuing Education
SDDCO can provide the direction your staff needs to keep current with FINRA member continuing education training requirements. Call on us to design and write an achievable Firm Element Continuing Education Program, which includes:
- A Firm Element Needs Analysis to identify the training needs of your firm’s staff
- A Firm Element Plan to describe the specific training and method of delivery
- A Firm Element Assessment to evaluate your firm’s progress toward its goals
Return to List of Compliance Services
Continuing Membership Application
If you plan to buy, sell, or restructure your broker/dealer’s ownership or expand into additional business lines, call upon SDDCO to manage your FINRA Continuing Membership Application (“CMA”) in accordance with FINRA's NASD Rule 1017. We can:
- Lead you through the application process
- Draft your application letter, any additional procedures, and process the required forms
- Help you gather and assemble the required FINRA information
- Respond to any additional documentation requests
New Member Application
If you plan to establish a new broker/dealer, partner up with SDDCO to streamline this painstaking process of preparing and filing your FINRA New Membership Application (“NMA”). We can:
- Provide expert ongoing advice and assistance
- Interface with FINRA examiners as needed
- Respond to information requests
- Help you accomplish the timely submission of a complete NMA including:
- A carefully constructed business plan
- Requisite standardized forms
- Various procedure manuals
- Biographies of your principals
- Preliminary financial statements
- Projections for 12 months of operation
Return to List of Compliance Services
Anti-Money Laundering Effectiveness
Brokerage firms and financial institutions are obligated to comply with the USA Patriot Act of 2001 and FINRA's NASD Rule 3011. SDDCO can:
- Draft and/or assist you to develop an anti-money laundering ("AML") program designed to detect and prevent the use of your firm to launder illegally disguised funds intended for or generated through criminal activities such as drug sales, robbery, fraud or terrorism
- Conduct an AML Effectiveness Testing engagement on-site in accordance with a comprehensive set of Agreed-Upon Procedures
- Prepare a comprehensive written report detailing the findings of the agreed-upon procedures engagement
Business Continuity Planning
Broker/Dealers are required and Investment Advisors are strongly recommended to have a written business continuity plan (BCP) in place that identifies a firm’s procedures for responding to significant business disruptions. SDDCO can work with your firm’s management to develop an effective and efficient plan designed to enable it to meet its existing obligations to customers.
Liaise with Regulators
Whether part of your Firm’s normal course of business or during a FINRA or SEC Firm Examination, SDDCO compliance professionals can assist your senior management by working closely with you or your firm’s legal counsel to draft correspondence with regulators.
Our Clients
The SDDCO Compliance Consulting Division specializes in regulatory issues for broker/dealers, registered investment advisors, and other investment establishments.
Our Approach
SDDCO tailors its expertise to fit your particular business model and to help you accomplish the goals of your compliance department.
We are proficient at updating policies and procedures, educating your staff, and documenting your compliance efforts. Our professionals will perform specific functions on behalf of your firm; monitor functions performed internally; and continually advise and reassess your needs. Our consultants study your company and connect with your management onsite to achieve a culture of compliance throughout your organization.
Our clients confirm that our hands-on method works best. We schedule onsite visits and give ongoing support via phone, email, and ad-hoc meetings. We do not sell one-size-fits-all compliance publications or provide anything "off-the-shelf". This personalized compliance support compliments our customized accounting and FinOp services. Engaging an interdepartmental team of SDDCO professionals is value-added and enables superior navigation across intricate financial, accounting and regulatory matters.