Operational Infrastructure for Scalable Broker-Dealers

Institutional-grade operating models built by people who've run operations at major broker-dealers and the firms that clear for them. Process design, vendor governance, outsourcing strategy, and program management — from the back office to the boardroom.

What We See Most

After running operations at Tier 1 institutions and advising firms through platform migrations, regulatory overhauls, and growth inflection points — these are the patterns we see over and over.

No Vendor Oversight Program

Firms relying on critical third-party vendors with no documented due diligence, no SLA enforcement, and no ongoing supervision. One vendor failure away from a regulatory finding and an operational crisis.

Manual Processes That Should Be Automated

Operations teams spending hours on reconciliation, break resolution, and report generation that could be straight-through processed. Over 50% of financial services organizations save $100K+ annually from automation they should have implemented years ago.

BCP Plans That Have Never Been Tested

Business continuity plans written to satisfy Rule 4370 but never exercised. When systems actually go down, the plan doesn't match reality — and the firm discovers its gaps under pressure instead of in a drill.

T+1 Workflows Still Running on T+2 Timelines

Settlement moved to T+1 in May 2024, but many firms haven't rebuilt their allocation, confirmation, and affirmation workflows around the compressed cutoff times. Every missed deadline is a settlement fail waiting to happen.

$2B+

Total SEC penalties for off-channel communication recordkeeping failures since 2021. Over 100 firms charged across six enforcement waves — a reminder that operational controls around books and records aren't optional.

SEC enforcement actions 2021–2025

Common Questions
FINRA Regulatory Notice 21-29 outlines a four-phase framework: deciding whether to outsource (distinguishing business activities from non-delegable regulatory obligations), conducting due diligence on prospective vendors (financial stability, cybersecurity posture, regulatory standing, BCP testing), onboarding with proper contractual protections (SLAs, right-to-audit, data ownership, sub-vendor restrictions), and maintaining ongoing supervision (performance reviews, periodic audits, monitoring for vendor changes). FINRA expects all of this to be documented and reviewable during an exam.
The move from T+2 to T+1 (effective May 2024 under SEC Rule 15c6-1) cut the settlement window in half. Under Rule 15c6-2, broker-dealers must now either use a matching service or maintain written policies with target timeframes for same-day allocations (by 7:00 PM ET), confirmations (by 9:00 PM ET), and affirmations (by end of trade date). Firms that relied on next-morning exception handling now need real-time or near-real-time processing, automated matching, and earlier cutoff times across their entire post-trade chain.
No. FINRA distinguishes between business activities (which can be outsourced) and regulatory obligations (which cannot). You can outsource the execution of operational tasks — trade processing, reconciliation, report generation — but the supervisory responsibility stays with your firm. This means you need a documented oversight program for every outsourced function, with regular performance reviews, compliance monitoring, and the ability to demonstrate to examiners that you're actively supervising the outsourced work.
FINRA's Cyber & Operational Resilience (CORE) program monitors technology and cybersecurity risks across the broker-dealer ecosystem. Through Q3 2025, it delivered over 6,000 notifications of cyber vulnerabilities impacting vendors to member firms. For your operations team, this means you need processes to receive and act on CORE notifications, maintain accurate vendor inventories, and integrate CORE intelligence into your vendor risk management program. Failing to respond to a CORE notification about a vendor you rely on creates both operational and regulatory exposure.
FINRA Rule 4370 requires your BCP to address data backup and recovery, alternative communications with customers, employees, and regulators, critical business function assessment, financial and operational assessments, customer access to funds and securities, and regulatory reporting during disruptions. The plan must be reviewed and updated annually, and your firm must conduct an annual review meeting. With the updated Reg S-P cybersecurity requirements (smaller firm compliance deadline: June 2026), incident response procedures must now also cover unauthorized access to customer information — extending BCP into active cyber incident management.

Ready to Transform Your Operational Infrastructure?

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