Broker-dealers and investment advisers are increasingly under pressure to conduct comprehensive reviews and assessments of their operations, policies, procedures and internal controls and to document those reviews. RRS tailors its audit programs to meet your firm’s needs and the requirements of the SEC and FINRA Rules. In fact, RRS provides multiple levels of service designed to meet or exceed regulatory requirements for the periodic review of a firm’s operations.
Supervisory Controls Testing
This service is designed to meet and exceed FINRA Rule requirements for annual testing of supervisory controls. In addition to assessing the adequacy of your firm’s compliance program and its written supervisory policies & procedures, RRS conducts high level testing to determine whether your firm’s procedures are being adequately implemented in compliance with applicable rules.
Written Supervisory Procedures Assessments
RRS will assess your firm’s overall compliance program, including internal controls and written compliance and supervisory policies and procedures to determine if they are reasonably designed to ensure compliance with industry rules and regulations. This service includes a comprehensive GAP analysis to identify areas of your firm’s business that are not adequately covered by a written policy or procedure.
Comprehensive Compliance Examinations
RRS’ most comprehensive service combines the assessment and examination with transaction level testing to identify potential violations or deficiencies. RRS’ testing practices involve statistical and risk-based sampling methodologies similar to those used by the SEC and FINRA. This service can cover a firm’s full business mix, or be customized to cover specific firm operations such as: Sales Practices, Trading and Market Making, MSRB Rule Compliance, Underwriting and virtually any aspect of a broker-dealer’s operations.
As uncomfortable as they may be, regulators are increasingly requiring firms to engage consultants to conduct independent reviews as part of settlement negotiations, and look to consultants that provide the regulatory background and insight to meet their expectations. RRS’ staff has extensive experience in this area, having served as Independent Consultant pursuant to numerous FINRA, SEC and State enforcement actions.
Regulatory Examination Support
RRS helps firms manage regulatory examinations to ensure efficient production of documents and reduce the regulatory burden. In fact, in certain situations, a consultant can be available onsite to assist your firm through the examination process, and help you respond to information and document requests from regulators.
AML Program Testing
RRS’ AML compliance testing service offers an in-depth review of your firm’s AML program to measure its effectiveness at detecting suspicious activity, monitoring OFAC compliance, and performing appropriate due diligence of customers so that your firm can meet the required element for independent annual testing of its AML program.