๐ค Employee Conduct & Reportable Events ยท Lesson 5 of 5 ยท 5 min
Supervision: Every Rep Has a Principal
๐ No one at a broker-dealer works unsupervised, not even the top producer. The rule behind that is FINRA 3110.
๐ก Key idea
Rule 3110: WSPs, a principal over every rep, annual compliance meeting, inspections (OSJ yearly, other branches every 3 years). See a red flag? Escalate to a supervisor or compliance.
๐ง Why it matters
FINRA RULE 3110 requires every member to run a SUPERVISORY SYSTEM: WRITTEN SUPERVISORY PROCEDURES (WSPs), a registered PRINCIPAL assigned to each rep, review of trades and correspondence, and an ANNUAL COMPLIANCE MEETING for every registered person. Offices are INSPECTED: an office of supervisory jurisdiction (OSJ) or a branch that supervises others at least ANNUALLY, other branches at least every THREE YEARS, non-branch locations periodically. Firms check U4 accuracy within 30 days of filing, and may place a rep with a disciplinary history under HEIGHTENED SUPERVISION (closer review, extra approvals). If something looks wrong (an odd wire request, a customer's confused complaint, a colleague's secret side deal) the right move is to escalate to your supervisor or compliance, not to investigate or fix it yourself.
๐ In the real world
๐ง A customer's 'new email address' asks Tasha to wire $40,000 to an overseas account today. It feels urgent and off. Rather than calling the number in the email, she escalates to her principal, who verifies with the customer by a known phone number. It was a hacked inbox; escalation saved $40,000.
๐ Takeaways
- 3110: WSPs and a designated principal for every registered person
- OSJs inspected annually; non-supervising branches at least every 3 years
- Red flags go to your supervisor or compliance right away
๐ Terms in this lesson
Written supervisory procedures (WSPs): A firm's written rules describing how it supervises its business and people to comply with securities laws.
โ Test yourself
How often must an office of supervisory jurisdiction (OSJ) be inspected under FINRA Rule 3110?
- At least annually
- Only after complaints
- Every month
- Every three years
Answer: A ยท At least annually
OSJs and branches that supervise non-branch locations are inspected at least annually. The three-year cycle applies to branches that supervise no other locations.
Which is required of every registered person under Rule 3110?
- A personal surety bond
- An annual compliance meeting
- A quarterly Form U4 refile
- A yearly in-person exam
Answer: B ยท An annual compliance meeting
Each registered person must take part at least annually in a compliance meeting or interview (it need not be in person). Bonds, refiled U4s and yearly exams are not 3110 requirements.
A rep notices a coworker taking cash from a customer for a deal not on the firm's books. What should the rep do?
- Ignore it unless the customer complains
- Confront the coworker privately
- Escalate to a supervisor or compliance
- Report it to the SEC anonymously first
Answer: C ยท Escalate to a supervisor or compliance
A possible selling-away or theft red flag should go promptly to a supervisor or compliance, who are responsible for investigating. Ignoring it or confronting the coworker alone can make things worse.
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More in Employee Conduct & Reportable Events
- 1Side Hustles: Tell Your Firm First
- 2Selling Away: The Deal Your Firm Never Saw
- 3Gifts, Dinners and Campaign Checks
- 4Your Own Accounts and Events You Must Report
- 5Supervision: Every Rep Has a Principal
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