Supervisory Controls Testing (FINRA Rule 3120)
Under FINRA Rule 3120, broker-dealers are required to have in place a system of policies and procedures that annually test and verify firm supervisory controls procedures. Firms must also create or amend Written Supervisory Procedures identified as necessary by this testing.
The designated principal or principals must submit to the member’s senior management no less than annually, a report detailing each member’s system of supervisory controls, the summary of the test results and significant identified exceptions, and any additional or amended supervisory procedures created in response to the test results.
Oyster will review and test your firm’s supervisory controls procedures, document the review, and work with your firm’s management to recommend ways to remediate any gaps and improve your firm’s control environment.
Your customized review will be based on how your firm operates, but will cover:
- Trading and Markets activity
- Investment Banking
- Anti-Fraud and Sales Practices
- Finance and Operations
- Anti-Money Laundering
The Oyster Difference
Oyster does not have a cookie-cutter, one-size-fits-all approach to 3120 testing. Our experts have years of industry experience and can quickly assess through thoughtful and skillful questions what areas of your firm need the most attention and review. In addition to identifying potential problem areas, Oyster will provide your firm with recommendations for operational enhancements to achieve industry best practices.