In May 2019, Bates Compliance published a review of the supervision, inspection and operational considerations for broker-dealer branch office compliance. In that paper, Bates described the core obligations on supervisors of broker-dealer branches taking into account FINRA's announced examination priorities as well as its guidance on strengthening cybersecurity controls.
Since then, FINRA has broadened those priorities to include compliance inspections on the new conduct standards obligations (Regulation Best Interest) and has continued to emphasize the importance of adopting a risk-based approach in firm compliance frameworks. The COVID-19 pandemic has heightened these risks, drawing significant attention to the future of supervision and practice over remote offices in general.
This updated white paper discusses the responsibilities placed on the supervisors of broker-dealer branches in light of FINRA's broadened priorities and recently updated guidance on remote supervision.