Description

A focused course, tailored for you

The Retail Broker-Dealer Compliance Manager Evidence Playbook

Turn Reg BI, supervisory reviews, and exception dispositions into one evidence record your CCO and exam team both work from.

The supervisory exception queue is half-resolved, the CCO needs the Reg BI disposition export by Friday, and the evidence trail lives across three tools and a shared mailbox.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

A retail broker-dealer compliance manager runs a weekly cadence of exception reports, branch supervisory reviews, Reg BI rollover and recommendation documentation, OBA disclosures, communications surveillance hits, and senior-supervisor escalations. The work itself gets done. The evidence record of who reviewed what, against which Written Supervisory Procedure, with what disposition reasoning, gets reconstructed when a FINRA exam request lands or when the CCO needs to brief the board risk committee. That reconstruction work eats the same week every quarter. The fix is not more reviews. The fix is a standing evidence structure that captures the disposition reasoning at the moment of review, in a shape an examiner can read without a translator, organised against the same WSP sections the exam team will cite. Once that structure exists, the exception-queue cleanup becomes a sort-and-export rather than a forensic reconstruction.

What you walk away with

Produce a Reg BI care-obligation evidence export for any time window in under an hour, not three days.
Hand a FINRA exam team a single supervisory-review file structure organised by WSP section, with disposition reasoning captured at the moment of review.
Cut the quarterly exception-report backlog cleanup from a week of reconstruction to a sort-and-export.
Brief the CCO and the board risk committee from the same evidence record, no separate decks required.
Document OBAs, outside accounts, and senior-supervisor escalations in a shape that does not generate deficiency-letter findings.

The 12 modules

Module 1. The Reg BI Care-Obligation Evidence Chain

The four obligations under Reg BI (Disclosure, Care, Conflicts, Compliance) and what evidence each one requires at the recommendation level. The care-obligation chain in particular: reasonable basis, customer-specific, and series-of-recommendations evidence, with downloadable disposition-note templates you can attach to the rep's recommendation record. Worked examples for rollovers, account-type recommendations, and complex-product approvals.

Module 2. Supervisory Branch-Review File Structure FINRA Opens First

The order a FINRA exam team actually opens files in: WSPs, the supervisory log, the exception register, the branch-review schedule, the senior-supervisor escalation log, the OBA register. Module covers the file-naming convention, the folder structure mirrored against WSP sections, and the index sheet examiners use to navigate. Template branch-review file structure included as a downloadable zip.

Module 3. The Written Supervisory Procedure Update Cycle

How to keep WSPs current with rule changes, internal product launches, and exam findings without rewriting the document every cycle. Covers the change-log pattern examiners credit, the annual attestation sign-off chain, and the version-control template that makes it trivial to show which version of which WSP was in force at the moment a given supervisory review happened.

Module 4. Exception-Report Disposition at the Moment of Review

Why the quarterly reconstruction work happens (disposition reasoning captured later, in summary, from memory) and what to put in place instead. A standing exception-report disposition template that captures the reviewer, the date, the WSP citation, the disposition reasoning, and the close-out evidence in one row, exportable to the CCO and to an examiner without rework. Worked example for the most-cited exception types.

Module 5. Rollover Recommendation Documentation

The single highest-risk Reg BI recommendation category for retail broker-dealers. Module covers the rollover analysis worksheet, the fee-comparison evidence, the alternative-considered documentation, the rep's rationale capture, and the supervisor's review evidence. Template rollover file included. Covers IRA-to-IRA, employer-plan-to-IRA, and IRA-to-employer-plan variants.

Module 6. Outside Business Activities and Outside Account Workflow

The OBA approval workflow, the outside-account 3210 letter pattern, and the standing review cadence that keeps both registers current. Module walks through the disclosure form, the supervisory approval chain, the conflict-of-interest analysis, the documentation of any restrictions imposed, and the annual attestation refresh. Template OBA register and 3210 letter library included.

Module 7. Communications Surveillance Evidence and Lexicon Tuning

Email and electronic communications surveillance: lexicon design, false-positive disposition documentation, true-positive escalation evidence, and the quarterly lexicon-tuning record. Module covers how to document the surveillance reviewer's reasoning when a hit is dispositioned as not-actionable, in a shape that does not look like rubber-stamping when an examiner reads it months later.

Module 8. Senior-Supervisor Escalation Log

The escalation chain from supervisory principal to senior supervisor to compliance to CCO. Module covers the escalation log structure, the decision-record pattern, the close-out evidence, and the quarterly review of escalation outcomes. Includes the pattern for documenting when an escalation results in a rep being placed on heightened supervision, including the heightened-supervision plan and the close-out criteria.

Module 9. Complex-Product Approval Evidence

Variable annuities, non-traded REITs, structured products, options, leveraged ETFs: the suitability and Reg BI evidence chain for each. Module covers the product-specific disclosure documents, the customer-acknowledgement evidence, the supervisory-approval workflow, and the post-trade review evidence. Worked examples for each product category, with template approval and review files.

Module 10. Customer Complaint Handling and the 4530 Reporting Decision

Complaint intake, complaint log, the analysis of whether a complaint triggers a 4530 filing, the filing itself, and the customer response. Module covers the documentation chain a FINRA examiner reads end-to-end on every complaint, the supervisory review of the complaint and the response, and the quarterly complaint-trend analysis the CCO uses to brief the risk committee.

Module 11. Annual Compliance Meeting and Training Evidence

The Rule 3110(a)(7) annual compliance meeting, the training-attendance evidence, the testing and attestation chain, and the documentation of any remedial training. Module covers the content cycle (what to cover this quarter vs deferred to next), the attendance-verification pattern, and the training-record file structure that ties each rep's training history to the rep's CRD.

Module 12. Exam Readiness and the Document Request Response

The mock-exam pattern that surfaces evidence gaps before a real exam does. Module covers the FINRA request-letter response workflow, the document-collection coordination across departments, the privilege-and-confidentiality review, the production log, and the close-out file. Includes the template request-response tracker and the post-exam findings-tracker that feeds back into the WSP update cycle from module 3.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

Friday Reg BI disposition export to the CCO becomes a saved query, not a week of work.

The next FINRA exam request letter lands and the document-collection workflow is already standing.

The quarterly exception-report backlog cleanup turns into a sort-and-export against the standing disposition template.

The board risk committee gets briefed from the same evidence record the CCO uses, not a separate deck.

What you get with this course

Twelve written modules with downloadable disposition, register, and file-structure templates.
Worked examples for Reg BI rollover documentation, complex-product approvals, and OBA workflows.
Mock FINRA exam request-response tracker and document-collection workflow.
The hand-built implementation playbook tailored to your firm's product mix and supervisory structure.

What you will have in hand by Day 1, Week 1, Month 1

Within 24 hours your account in the learning environment is provisioned and the hand-built implementation playbook is delivered alongside it.

Modules 1 through 4 in the first week build the Reg BI and exception-disposition foundation.

Modules 5 through 8 in the second week cover rollovers, OBAs, surveillance, and the senior-supervisor log.

Modules 9 through 12 in the third and fourth weeks cover complex-product evidence, complaints, training, and exam readiness.

Before and after

Before

Quarterly exception-report cleanup eats a week. Reg BI evidence lives across three tools and a shared mailbox. The CCO asks for a disposition export and the answer is a multi-day reconstruction.

After

Disposition reasoning is captured at the moment of review. The branch-review file structure mirrors the WSP sections an examiner cites. The CCO export is a saved query. The exam request-response workflow is already standing when the request letter lands.

What happens if you do not address this

The next FINRA exam request lands on the existing evidence structure. The reconstruction work that has been deferred each quarter becomes the exam team's first impression. Deficiency-letter findings on supervisory recordkeeping and Reg BI evidence are among the most frequent FINRA citations against retail broker-dealers, and they compound into heightened supervision orders.

Who it is for

Compliance Manager inside a retail broker-dealer, sitting between the front-line supervisory principals and the CCO. Owns the cadence of supervisory reviews, the Reg BI evidence chain, OBA and outside-account workflows, exception-report dispositions, and the exam-readiness file structure. Reports up to the CCO and across to Legal and the senior supervisor population. Holds Series 7, 24, 66 or equivalents.

Who this is NOT for. AML-only analysts, registered representative supervisors who do not own evidence structure, institutional desk compliance officers whose product mix is dealer-dealer rather than retail Reg BI, or anyone outside a US broker-dealer regulated by FINRA.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Plan on three to five hours per module, mostly in the templates and the worked examples. Total runway is four to six weeks at a working compliance manager's pace, faster if a quarterly cleanup deadline is forcing the issue.

Why $199 is the right number

FINRA's published exam findings reports tell you what gets cited. They do not give you the file structure that prevents the citation. NSCP conference sessions cover regulatory developments but rarely the evidence-chain mechanics. Internal-only WSP updates fix the document, not the disposition-capture workflow. This course is the workflow and the templates, organised against the WSP sections an examiner actually opens.

FAQ

Does this cover dual-registered RIA-side recordkeeping?

The course is built for the broker-dealer side. RIA-side recordkeeping has overlap (the Advisers Act recordkeeping rule, Form ADV evidence) but a different evidence shape. The implementation playbook can be tuned to your dual-registered structure if you flag it on intake.

Is the Reg BI material current to the SEC's most recent staff bulletins?

Yes. The care-obligation module incorporates the SEC staff bulletin guidance on conflicts, account-type recommendations, and complex products. Updates ship to enrolled students when the SEC issues new staff guidance.

What if our firm uses a third-party surveillance platform?

Module 7 covers lexicon design and disposition-evidence patterns that are platform-agnostic. The templates work on top of whatever surveillance platform the firm uses.

Is the implementation playbook generic or tailored?

Tailored. The playbook is hand-built within 24 hours of enrolment, against the firm's product mix, supervisory structure, and the specific evidence gaps you flag on intake.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.