AuditsCompliance-in-a-Box: The Startup Guide to Audit-Ready DocsSVSid Varma · 12 min readFor broker-dealer CCOs and supervising principals who maintain WSPs, run the annual compliance meeting, and prepare the 3120 report and 3130 certification.
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Checked against primary sources on 18 October 2026.
Every FINRA member broker-dealer must establish and maintain a supervisory system and written procedures for its associated persons and each type of business it conducts.
FINRA examiners in cycle, cause and branch examinations, with document requests made through FINRA's Request Manager
Annual compliance meeting, annual 3120 report and 3130 certification; OSJs inspected annually, other branches at least every three years; FINRA cycle exams set by risk, up to six years for some lower-risk firms
FINRA Rule 3110 as amended, including Supplementary Material .18 (remote inspections pilot) and .19 (residential supervisory location) adopted in Regulatory Notice 24-02, 2024-07-01. Free to read.
| Date | What happens | Status |
|---|---|---|
| 2025-12-10 | FINRA publishes its 2026 Annual Regulatory Oversight Report | Done |
| 2026-07-20 | FINRA announces that certain lower-risk member firms are now examined every six years, with ongoing risk monitoring | Done |
| 2027-06-30 | Remote Inspections Pilot Program under Rule 3110.18 is scheduled to expire unless extended or made permanent | Scheduled |
Each one needs an owner, an approval, and proof it reached the people it covers.
FINRA Rule 3110(b)(1)
Written procedures to supervise each type of business the member conducts and the activities of its associated persons, reasonably designed to achieve compliance with securities laws and FINRA rules.
FINRA Rule 3110(b)(7)
The member promptly amends its WSPs as laws, rules and its supervisory system change, and promptly communicates the procedures and amendments to the associated persons they affect.
FINRA Rule 3110(a)(7)
Each registered representative and principal takes part, at least annually, individually or in a group, in an interview or meeting covering compliance matters relevant to their activities.
FINRA Rule 3110(c)(1)-(2)
Each inspection is reduced to a written report kept for at least three years; OSJs are inspected annually and other branch offices at least every three years.
FINRA Rule 3120(a)
Designated principals test and verify the supervisory procedures and report to senior management at least annually, summarizing test results, significant exceptions and procedures added or amended.
FINRA Rule 3130(b)-(c)
The CEO signs an annual certification that the firm has processes to establish, maintain, review, test and modify written compliance policies and WSPs, evidenced in a report produced beforehand.
Citations are to the standard or regulation; wording is ours.
What reviewers sample about these documents and the people they cover.
Expect requests through Request Manager for the WSPs in effect during the review period, the amendments made, and how each amendment reached the associated persons it affects under Rule 3110(b)(7).
Because Rule 3110(a)(7) requires each registered representative and principal to take part at least annually, firms are asked to show who attended, when, and which compliance matters were discussed.
The annual supervisory controls report to senior management, the CEO certification, and the report evidencing the firm's processes, which Rule 3130 requires to exist before the certification is signed.
Written inspection reports for OSJs and branch offices, kept at least three years, showing the inspection cycle assigned to each location and the findings recorded.
Write each policy, send it through approval, and send it to the people it covers. Each acknowledgment is recorded by name, with the version, the date and the time.
When a policy changes, the new version is approved, its Editor sends it out again, and everyone it applies to is asked again. Export the record as a PDF or CSV, or give a reviewer Viewer access to the documents their tags allow.
Need help with the rest of FINRA Rule 3110? Find a consultant for your standard (opens in a new tab).
Your region’s laws, the standards your customers ask for, and your own house rules. Write each one as a policy, approve it, and send it to the people it covers.
Rule 3110(b)(7) requires the member to amend its WSPs promptly as laws, rules and its supervisory system change, and to communicate the procedures and amendments promptly to associated persons for whom they are relevant. The rule sets no fixed number of days.
Rule 3110(a)(7) allows participation individually or collectively, in an interview or meeting conducted by persons the member designates. It must occur no less than annually and cover compliance matters relevant to the participants' activities.
A member that reported $200 million or more in gross revenue in the prior calendar year adds a tabulation of customer complaint and internal investigation reports made to FINRA. It also discusses the prior year's compliance efforts in six areas, including supervision and anti-money laundering.
It added Rule 3110.19 for residential supervisory locations, effective June 1, 2024, and the Rule 3110.18 remote inspections pilot, effective July 1, 2024. The pilot is scheduled to expire on June 30, 2027 unless extended or made permanent.
Rule 3110(c)(2) requires each inspection to be reduced to a written report kept for at least three years. Where a non-branch location runs on a periodic schedule longer than three years, the report is kept until the next inspection report is written.
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