Case Study 1: Examination Readiness and Remediation for Regi

Background   A regional broker‑dealer with 45 registered representatives and three branch offices engaged us after receiving notice of an upcoming SEC/FINRA examination and identifying weaknesses in supervisory documentation and AML controls.

Challenge   The firm lacked up‑to‑date Written Supervisory Procedures, had inconsistent trade surveillance escalation, and could not demonstrate recent independent AML testing—creating elevated exam risk.

Approach   We performed a rapid firm‑wide risk assessment, prioritized remediation items, and executed a 6‑week readiness program that included drafting WSPs, redesigning exception workflows, and conducting targeted AML testing. We ran mock exam sessions with leadership and prepared a complete exam response binder.

Outcome and client benefit   The firm entered the exam with clear, auditable documentation and a remediation log; examiners closed the review with only minor procedural observations. Leadership reported improved confidence in supervisory oversight and a 40% reduction in open compliance action items within 90 days.

Deliverables

• New WSPs and compliance manual;
• AML testing report and remediation plan;
• Mock exam report and examiner response binder;
• 90‑day remediation tracker and board briefing.

Background   A newly formed broker‑dealer launching fixed income and advisory services needed help with registration, Form BD filings, and interim compliance leadership while hiring a permanent CCO.

Challenge   The founders were unfamiliar with SEC/FINRA registration nuances, required a compliant AML program, and needed immediate policies and training to onboard reps and vendors.

Approach   We guided the registration process, prepared Form BD and supporting exhibits, drafted core policies including AML and business continuity, and provided fractional CCO services for the first six months. We also delivered role‑based onboarding training and vendor due diligence templates.

Outcome and client benefit   The firm completed registration on schedule, launched with documented compliance controls, and onboarded reps with standardized training. Our interim CCO support allowed the founders to recruit a permanent CCO without operational gaps and ensured the firm met initial regulatory milestones.

Deliverables

• Form BD package and registration checklist;
• AML program, WSP highlights, and BCP;
• Fractional CCO monthly reports and board updates;
• Onboarding training materials and vendor due diligence templates.

Background   A national broker‑dealer relied on multiple third‑party vendors for custody, order routing, and cloud services but had inconsistent vendor oversight and no centralized vendor risk register. Leadership worried about operational and regulatory exposure from vendor failures.

Challenge   The firm lacked standardized vendor onboarding, risk scoring, and contract clauses that satisfy SEC expectations for vendor oversight and data protection, increasing audit and business‑continuity risk.

Approach   We created a vendor governance framework including a vendor risk matrix, standardized due‑diligence questionnaires, contract playbook language, and a centralized vendor register. We ran risk assessments for the top 20 vendors, negotiated stronger SLAs and security commitments, and trained procurement and compliance teams on ongoing monitoring triggers.

Outcome and client benefit   The firm gained a defensible vendor oversight program, reduced high‑risk vendor exposure by 35%, and produced documentation that satisfied examiners and internal auditors. Procurement and compliance now follow a repeatable onboarding process that shortens vendor approval time while improving controls.

Deliverables

• Vendor risk matrix and centralized register;
• Due‑diligence questionnaire and contract playbook;
• Top‑vendor remediation plans and SLA amendments;
• Training session and monitoring playbook.

Background   A regional advisory and brokerage firm experienced inconsistent suspicious activity reporting and received examiner comments about SAR quality and timeliness.

Challenge   Investigations were under‑documented, SAR narratives lacked sufficient detail, and transaction monitoring thresholds produced both missed alerts and excessive false positives.

Approach   We performed a targeted AML remediation engagement: redesigned alert scenarios, recalibrated monitoring thresholds, implemented a standardized investigation template, and ran a series of quality reviews on historical SARs. We also delivered role‑based training for investigators and compliance leadership on SAR drafting and escalation criteria.

Outcome and client benefit   SAR quality and timeliness improved measurably; the firm reduced false positives by 45% and produced a documented quality‑control process that examiners accepted. The compliance team reported faster investigations and clearer decision trails for reporting decisions.

Deliverables

• Recalibrated monitoring rules and tuning log;
• Investigation templates and SAR drafting guidelines;
• Historical SAR quality review report and remediation plan;
• Investigator training and ongoing QA checklist.