Compliance Services

AML Auditing & Reporting

FINRA Rule 3011 requires that ALL firm, regardless of their business or size, develop and implement a written AML program that is reasonably designed to achieve and monitor compliance with the requirements of the Bank Secrecy Act.    Firms are also required arrange for independent testing of the AML program for compliance with the rule.

This test may be conducted by internal qualified personnel or a qualified outside party.  Unfortunately, most small firms can not satisfy the “independent” requirement of the rules.

That’s where B/D Solutions Consulting comes in

Our AML professionals are members of the Association of Certified Anti-Money Laundering Specialists (ACAMS), and hold the CAMS (Certified Anti-Money Laundering Specialist) designation.

Our AML Audit examines the key components identified by the regulators as essential for an effective AML program including:

• Written Supervisory Procedures and program documents related to AML including previous audit results and subsequent program updates
• Firm risk and exposure with respect to size, business lines, customer base and geographic location
• Customer identification and verification procedures including checking federal lists
• Procedure and review activities for monitoring suspicious activity including provisions for confidentiality
• Record keeping and retention procedures
• Reliance relationships and supporting documents
• Training program content and scope

The AML audit package includes:

• Comprehensive report with point by point results for Senior Management review
• Recommendations for enhancing the efficiency of your AML Program if warranted
• Follow-up support to complete any updates recommended
• Reporting and review procedures for Suspicious Activity including electronic systems

We look forward to planning your AML Program compliance testing today.

Written Supervisory Procedures (WSP)

Bigger procedures are not better procedures.  Our approach is different – we believe in developing procedures which are comprehensive, yet well-organized and easy to follow.   Procedures containing nonessential detail often cause problems rather than prevent them.   FINRA will hold your firm to its current set of written rules, regardless of how insignificant a deviation may exist.  We will help you develop procedures that will ensure full compliance and satisfactory supervision, yet allow your firm the flexibility necessary to meet the realistic demands of business.

We offer a solution for every need. We can:

• Create a new set of procedures from start to finish.   Our comprehensive procedures detail the who, what, how, when and where of supervising activities. We cover the entire range of supervision, from designation of responsibilities to supervision of customer accounts.

• Review and update your current procedures.   Our professionals will make sure that your procedures fulfill FINRA’s requirement of establishing and maintaining a system to supervise the activities of registered representatives and associated persons. We will review your firm’s existing set of procedures and suggest updates and enhancements that will bring it into compliance.

• Monitor and maintain your firm’s procedures.  Clients enrolled in our Written Supervisory Procedures Maintenance Plan receive routine evaluations of manuals, with up-to-the-minute procedures added as FINRA and the SEC establish new rules and regulations.

Let us review, monitor and maintain your Written Supervisory Procedures – so you can focus on growing your business.

Supervision System Design

B/D Solutions can help re-design and implement supervision systems, craft meaningful Written Supervisory Procedures, structure, broker dealer compliance workflows for geographically diverse branches, utilize technology to facilitate compliance, specialize in independent contractor issues.

CEP Planning

B/D Solutions focuses on helping brokerage firms and banks plan and implement meaningful Continuing Education Programs (CEP).  We do not create, publish or distribute proprietary CEP material, so we won’t try to sell you booklets, CD’s, or other materials.

B/D Solutions believes that a CEP can be a useful and effective tool in developing and communicating your corporate strategy. If designed properly, regulatory requirements and expenses can be turned into beneficial communication tools for your firm. Many times, we are able to document and formalize organizational information and training materials currently in use to meet CEP requirements.

B/D Solutions provides the following CEP Planning Services:

• Conduct the Annual CE Needs Assessment
  • Review prior year’s CEP effectiveness
  • Evaluate current year needs and trends
  • Anticipate future potential issues

• Develop a Current Year Continuing Education Plan
  • Define purpose and scope
  • Identify target CEP segment
  • Select specific topics
  • Create timetable for implementation
  • Develop a system for documentation and record keeping

• Create Customized Continuing Education Programs
  • Design large group discussion & training sessions
  • Establish Branch Manager and OSJ Manager training programs
  • Create seminar and conference workshops and round tables
  • Develop lunchtime CE programs for small and/or limited scope B/D’s

Mock Regulatory Exam

B/D Solutions will conduct the same regulatory examinations that FINRA may sometimes give your Home Office, OSJ, or Branch Office. The benefits of mock regulatory examinations include early detection of possible compliance issues, a general understanding of the FINRA examination procedure, and prevention of an issuance of a fine should FINRA conduct an examination of your firm.

Regulatory Response Assistance & Review

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Prevent Regulatory Problems

B/D Solutions has a staff of experienced professionals who are highly qualified to conduct special investigations on an array of securities topics and problems.

Every brokerage firm has experienced the need to quickly uncover wrongdoing in order to manage damage control. Many firms use our staff to investigate “reg flags” in order to detect and prevent regulatory problems.

• Examine rogue/statutorily disqualified registered representatives.
• Resolve Net Capital violations and accounting reconciliations.
• Investigate allegations of churning and unauthorized transactions.
• Conduct internal audits and reviews of books and records.

Expertise on Retainer

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B/D In the Cloud

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