Modernizing the Infrastructure Behind Broker-Dealer Oversight

We build the technology layer that makes compliance, surveillance, and operations actually work — from platform selection and data architecture to automated reporting and real-time telemetry. Built by people who've operated these systems at scale, not just sold them.

What We See Most

After years building and operating technology platforms at institutional broker-dealers, these are the patterns we find at nearly every firm we assess.

Legacy System Limitations

Outdated surveillance and recordkeeping platforms that lack configurability, creating blind spots in coverage and exposing firms to regulatory findings they can't defend against.

Data Silos and Manual Processes

Fragmented data across disconnected systems preventing holistic oversight. Manual reconciliation creating latency and error risk in workflows that should be straight-through processed.

Vendor Technology Blind Spots

Reactive rather than proactive third-party technology oversight. Firms relying on vendor-default configurations without understanding what those defaults actually cover — and what they miss.

No Telemetry or System Health Monitoring

Lack of embedded performance metrics and capacity tracking. Firms discovering SCI events, surveillance failures, or processing bottlenecks after the damage is done instead of before.

$6.08M

Average cost of a data breach in financial services — 22% higher than the global average. The firms that invest in surveillance automation, access controls, and incident response programs spend a fraction of that on prevention.

IBM Cost of a Data Breach Report — 2024

Common Questions
Regulation SCI requires certain entities to maintain critical technology systems with high levels of capacity, integrity, resiliency, availability, and security — and to report disruptions or intrusions to the SEC. Currently it applies to SCI entities including certain ATSs and exchanges, but proposed amendments would extend it to broker-dealers exceeding specific asset or activity thresholds. Even if your firm isn't currently an SCI entity, the operational standards Reg SCI establishes are increasingly what examiners expect to see.
The Consolidated Audit Trail requires broker-dealers to capture and report detailed order lifecycle data across all eligible securities. This demands robust data infrastructure to handle high-volume reporting, error correction workflows, and integration with your order management systems — while maintaining accuracy and timeliness. FINRA examinations consistently find incomplete submissions and failure to timely repair errors. We design data pipelines and validation frameworks that make CAT compliance a byproduct of clean architecture rather than a manual reconciliation exercise.
Rule 17a-4 requires broker-dealers to preserve electronic records with audit-trail capabilities that can recreate original records if modified or deleted. The 2022 amendments made the rule technology-neutral, replacing the legacy WORM (write once, read many) requirement with an audit-trail alternative. This gives firms flexibility in system design while maintaining stringent preservation and accessibility standards for regulatory review. We help firms modernize their recordkeeping infrastructure to take advantage of that flexibility.
FINRA examinations frequently identify unreasonable surveillance parameters that generate excessive false positives or miss real patterns, failure to review alerts from automated systems, coverage gaps across institutional accounts and affiliates, and reliance on legacy platforms that can't be configured to your firm's actual trading activity. Many firms also lack surveillance for off-channel communications and trading activity outside traditional investment banking channels. We design surveillance programs that address these exact findings.
Financial services firms face the highest per-incident breach costs of any sector at $6.08M on average. But the math works in favor of prevention: incident response teams save approximately $248K annually, and identity and access management solutions save approximately $223K. With the SEC's 2024 Reg S-P amendments requiring written incident-response programs and 72-hour vendor breach notification, cybersecurity is no longer optional infrastructure — it's a regulatory requirement. We help firms prioritize investments where the risk reduction is highest relative to cost.

Ready to Modernize Your Technology Infrastructure?

Three founding partners. Six disciplines. One team dedicated to your firm's transformation.