FINRA Compliance Programs

FINRA-registered broker-dealers operate under one of the most demanding regulatory supervisory frameworks in the financial services industry. FINRA Rule 3110 requires each member firm to establish, maintain, and enforce a supervisory system — including written supervisory procedures — reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA rules. The obligation extends beyond having written policies on file. Examiners evaluate whether the supervisory system functions as designed, whether supervisors are actually reviewing what the procedures require them to review, and whether exception reports and red flags are being acted upon.

Annual compliance certification under FINRA Rule 3130 requires each member firm's chief executive officer to certify — in writing — that the firm has processes to establish, maintain, review, test, and modify its written supervisory policies and procedures. This certification obligation makes the quality and defensibility of your compliance program a C-suite matter. Doo Compliance builds compliance programs that the CEO can certify with confidence because we build them to be defensible, not decorative.

AML compliance under FINRA Rule 3310 presents particular complexity for broker-dealers. The rule requires a written AML program, independent testing, and annual training — but the substance of what qualifies as adequate varies significantly based on business model. A firm engaged in equities clearing has fundamentally different AML risk exposure than an introducing broker focused on private placements. We build AML programs scaled to the actual risk profile of your business, not copied from a generic template.

Regulation Best Interest has reshaped the standard of conduct for retail-facing broker-dealers. The care obligation requires firms to document the basis for recommendations — including consideration of costs, reasonably available alternatives, and the specific investment profile of the retail customer. Our FINRA compliance programs include Reg BI implementation frameworks, care obligation documentation workflows, conflict of interest disclosure review, and Form CRS drafting and amendment support.