Compliance Infrastructure for Broker-Dealers

Robust supervisory systems, regulatory exam readiness, and continuous monitoring — built by operators who've done the work inside firms like yours.

What We See Most

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.

Outdated WSPs & SOPs

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.

Weak Supervisory Designation

Unclear lines of responsibility — no named supervisors for specific functions, missing escalation paths, or delegation gaps that leave activities effectively unsupervised.

Reporting Infrastructure Gaps

CAT, CAIS, and TRF submissions with recurring exceptions, missing data quality controls, or no process for identifying and correcting errors before they compound.

Untested Controls

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.

22%

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

Common Questions
We start by mapping your firm's actual operations — what your team does day to day, who's responsible for what, and where existing procedures diverge from reality. From there, we draft updated WSPs and SOPs that reflect your current business, designate responsible individuals, and establish clear escalation paths. The timeline depends on the size and complexity of your firm, but the goal is always operational procedures — not shelf documents.
We run mock examinations that mirror the real process — document requests, personnel interviews, supervisory system walkthroughs. We identify where findings are most likely, build remediation plans for anything that surfaces, and coach your team on how to handle examiner questions. Our partners have been on both sides of the exam table, so we know what examiners look for and how they prioritize.
A strategic assessment is a point-in-time evaluation — we audit your compliance infrastructure, identify gaps, and deliver a prioritized roadmap. Continuous monitoring is an ongoing program where we test controls regularly, track regulatory changes that affect your firm, and surface issues before they become exam findings. Most firms start with an assessment and move into monitoring once the foundation is solid.
Yes. We support firms through active FINRA, SEC, and MSRB examinations — managing document production, preparing personnel, coordinating responses, and developing remediation plans for any findings. If you're already in an exam and need support, we can engage quickly.
The annual independent test is designed to be comprehensive, but in practice many firms receive surface-level reviews that verify policies exist without testing whether controls actually work. Our reviews evaluate operational effectiveness — whether your transaction monitoring is calibrated correctly, whether your team can execute the procedures as written, and whether your program meets the full regulatory standard. We close the gap between what's documented and what's operational.

Ready to Strengthen Your Compliance Infrastructure?

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