All member firms must have Written Supervisory Procedures on hand that explain how they comply with all of FINRA’s policies. These act as an operating manual for the firm. The Written Supervisory Procedures will many times be tailored to the particular firm they are written for to adequately represent the specific nature of the firm’s business. These procedures will outline who is responsible for supervisory procedures, the types of reviews that are required, when the reviews should be performed, and how they should be documented.

Effective Written Supervisory Procedures should include, but are not limited to, the following items:
  • portfolio management processes, including allocation of investment opportunities and consistency with investor goals, adviser disclosure, and applicable regulatory restrictions;
  • trading practices;
  • proprietary trading of the adviser and personal trading of supervised persons;
  • accuracy of public disclosures;
  • safeguarding client assets from inappropriate use;
  • recordkeeping and document retention policies;
  • marketing advisory services;
  • processes to value client holdings and assess fees based on such valuations;
  • client privacy safeguards, and
  • business continuity plans.
These policies and procedures are required and adopted by all registered investment advisers to prevent violations of the Advisers Act by the firm or any of its supervised persons.

The experts at Cobia Compliance will work with your firm to determine a customized set of Written Supervisory Procedures that will adequately reflect the needs of your firm as well as the supervised persons in it. Cobia will create the unique procedures that are required to meet the unique nature of each client. Contact Cobia today for a consultation of how they can provide Written Supervisory Procedures for your firm.