Robust supervisory systems, regulatory exam readiness, and continuous monitoring — built by operators who've done the work inside firms like yours.
After years inside broker-dealers and on the examiner side, these are the gaps we find most often — and the ones that carry the most risk.
Procedures that haven't been updated to reflect current operations, personnel changes, or recent rule amendments. Examiners notice immediately when your written procedures don't match what your team actually does.
Unclear lines of responsibility — no named supervisors for specific functions, missing escalation paths, or delegation gaps that leave activities effectively unsupervised.
CAT, CAIS, and TRF submissions with recurring exceptions, missing data quality controls, or no process for identifying and correcting errors before they compound.
ICOC frameworks and AML programs that exist on paper but haven't been tested against real scenarios. Controls that aren't tested are controls you can't rely on — and regulators know it.
Rise in FINRA enforcement actions year over year. The regulatory environment is tightening — and firms without strong supervisory infrastructure are the ones getting found.
FINRA Enforcement Data
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