Description

A focused course, tailored for you

The Wealth and Brokerage Compliance Testing Playbook

Turn FINRA exam findings, Reg BI Care Obligation gaps, and WSP weaknesses into closed corrective actions an examiner can reread without follow-up questions.

The Reg BI Care Obligation finding will not stay closed because the corrective action lived in a memo, not in a documented, repeatable testing program with sampling logic, reviewer sign-off, and an exhibit pack that survives the next FINRA exam cycle.

$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

Senior compliance managers at US broker-dealers carry a testing program that has to satisfy FINRA Rule 3110 supervision, Reg BI Care and Disclosure obligations, the SEC Marketing Rule for the advisory side, AML/BSA monitoring under the customer identification program, and books-and-records under SEA Rule 17a-4. The pressure point is not the rules. The pressure point is the moment an examiner asks for the testing methodology, the sample selection rationale, the exception aging, and the evidence that corrective actions actually changed rep behaviour. When the answer is a memo and a paragraph added to the WSP, the finding reopens. When the answer is a documented testing program with sampling logic, reviewer attestations, exception tracking, and a rep-level rollup, the finding closes and stays closed. This course teaches the second answer.

What you walk away with

A documented Reg BI Care Obligation testing program with sampling logic, reviewer sign-off, exception aging, and a rep-level rollup that survives reread by a FINRA examiner.
A written supervisory procedure rewrite that ties each testable obligation to a specific test, a specific reviewer, a specific exception path, and a specific evidence artefact.
A corrective action pipeline that converts every exam finding into a closed loop with documented behaviour change at the rep level, not a memo and a WSP paragraph.
An exhibit pack template the examiner can reread cold and reach the same conclusion the firm reached.
A supervision cadence that catches the Care Obligation gap before the next exam letter, not after.

The 12 modules

Module 1. Reading the FINRA exam letter as a testing program brief

How to read the most recent FINRA exam letter as a brief for the testing program rewrite. The letter names the obligations the examiner cared about, the evidence they wanted, the gaps they found, and the corrective actions they accepted in past cycles. This module shows how to map each finding to a specific testable obligation, a specific sample population, and a specific evidence artefact that closes the loop for good.

Module 2. Reg BI Care Obligation testing end to end

The Care Obligation is the obligation most often reopened in broker-dealer exams. This module builds the Care Obligation testing program from sample design through reviewer sign-off. Topics include recommendation population definition, sampling stratification by rep tier and product type, the reviewer rubric for reasonable basis and customer-specific suitability, the exception path, and the evidence artefacts that satisfy a reread by a senior examiner.

Module 3. Reg BI Disclosure Obligation testing and Form CRS reconciliation

Disclosure Obligation testing has to reconcile the relationship summary, the rep-level disclosures, the conflict disclosures, and the actual recommendation evidence in the file. This module builds the disclosure testing program, the Form CRS reconciliation step, the rep attestation cycle, and the exception path when a disclosure delivery cannot be evidenced. Includes the evidence binder template the examiner reads.

Module 4. FINRA Rule 3110 supervisory system testing

Rule 3110 requires a documented supervisory system, written supervisory procedures, internal inspections, and supervisory control testing. This module walks through testing each layer of the supervisory system, the branch inspection cadence, the supervisory control test design, the documentation that survives an exam reread, and the rep-level rollup that connects supervisory test results back to individual rep behaviour.

Module 5. Written supervisory procedure rewrite that holds

Most WSP rewrites add a paragraph and stop. This module rewrites the WSP so each testable obligation maps to a specific test, a specific reviewer, a specific exception path, and a specific evidence artefact. Includes the version control discipline, the annual review cycle, the rep training tie-in, and the supervisor attestation step that closes the loop on every change.

Module 6. SEC Marketing Rule testing for the advisory side

If the firm runs an advisory arm, the SEC Marketing Rule sits next to Reg BI in the testing population. This module builds the Marketing Rule testing program covering performance presentations, testimonials and endorsements, hypothetical performance, third-party ratings, and the recordkeeping required to evidence each. Includes the reviewer rubric, the sampling logic, and the exhibit pack format the SEC examiner reads.

Module 7. AML and BSA monitoring testing under the customer identification program

The AML testing program has to evidence the customer identification program, the customer due diligence cycle, the suspicious activity monitoring, the OFAC screening, and the SAR filing discipline. This module builds the AML testing program with sample selection by risk tier, reviewer sign-off, exception aging, and the audit trail that satisfies both internal audit and the next FINRA AML exam module.

Module 8. Books and records testing under SEA Rule 17a-4

SEA Rule 17a-4 governs the records the firm has to keep, the format, the retention period, and the WORM storage requirement for electronic records. This module tests the books-and-records program: communications retention, supervisory review evidence, the rep-level email and chat capture, the social media supervision queue, and the evidence the examiner uses to test whether the record was preserved in compliant form.

Module 9. Branch inspection program and the supervisory control test

Branch inspections and supervisory control testing are where the senior manager sees rep behaviour in the field. This module builds the branch inspection cadence, the on-site testing rubric, the supervisor interview format, the file review sample, and the supervisory control test that connects branch findings back to the firm-wide testing program rollup.

Module 10. Customer complaint surveillance and the rep-level pattern view

Customer complaint volume, type, and resolution pattern is one of the strongest leading indicators of rep-level supervisory gaps. This module builds the complaint surveillance program, the rep-level pattern view, the escalation path when a pattern emerges, and the corrective action tie-in that loops complaint findings back into the supervisory testing population.

Module 11. Corrective action pipeline and the rep-level behaviour change loop

Corrective actions only count if they change rep behaviour. This module builds the corrective action pipeline: finding logging, root cause analysis, control redesign, rep training, supervisor attestation, and the post-action testing cycle that evidences whether behaviour actually changed. Includes the evidence artefacts the examiner uses to test whether prior corrective actions held.

Module 12. The exam exhibit pack and the senior manager handoff

The final module assembles the exhibit pack the FINRA or SEC examiner reads. Walks through the testing program documentation, the sampling logic, the reviewer attestations, the exception aging, the corrective action evidence, the WSP rewrite, and the senior manager handoff conversation. The exhibit pack lets an examiner reread cold and reach the same conclusion the firm reached, which is the conclusion that closes findings and keeps them closed.

How this addresses your situation

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

Last FINRA exam letter cited the Reg BI Care Obligation testing as inadequate, and the corrective action lived in a memo and a WSP paragraph rather than a documented repeatable program. Modules 1, 2, 5, and 11.

SEC examiners on the advisory side are testing Marketing Rule compliance and the firm has not yet rebuilt the testing program around the rule's performance presentation and testimonial provisions. Modules 6 and 12.

AML exam module is in the rolling cycle and the customer identification program, customer due diligence, and SAR filing testing needs a documented sampling and reviewer rubric that survives reread. Module 7.

Branch inspection findings are not feeding back into the firm-wide supervisory testing rollup, so the same gap shows up branch by branch instead of being treated as a systemic control failure. Modules 9, 10, and 11.

What you get with this course

Twelve self-paced written modules covering the full senior-manager testing program for a US broker-dealer with an advisory arm.
Downloadable templates: testing program charter, WSP rewrite template, sampling logic worksheet, reviewer rubric library, exception aging tracker, corrective action pipeline tracker, exhibit pack template.
Worked examples for the Reg BI Care Obligation testing program, the Marketing Rule testing program, the AML testing program, and the books-and-records testing program.
The hand-built implementation playbook tuned to the firm's testing population, supervisory structure, and most recent FINRA exam findings.

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

Within 24 hours: course access provisioned in the Art of Service learning environment, all twelve written modules unlocked, downloadable template pack delivered.

Within 24 hours: hand-built implementation playbook delivered alongside course access, tuned to the firm's testing population and most recent exam findings.

Self-paced study: typical senior manager completes the twelve modules over a working fortnight while running the testing program in parallel.

Before and after

Before

Reg BI Care Obligation findings reopen exam after exam because the corrective action lived in a memo and a WSP paragraph rather than a documented testing program with sampling logic, reviewer sign-off, exception aging, and rep-level behaviour change evidence.

After

Each testable obligation has a specific test, a specific reviewer, a specific exception path, a specific evidence artefact, and a corrective action pipeline that evidences behaviour change at the rep level. The exhibit pack lets the examiner reread cold and reach the firm's conclusion.

What happens if you do not address this

The next FINRA exam cycle reopens the Care Obligation finding, escalates the supervisory control gap, and adds Marketing Rule findings on the advisory side. The cost is not the fine. The cost is the senior manager spending the next cycle responding to repeat findings instead of running a clean program.

Who it is for

A senior manager of compliance at a US wealth management or broker-dealer firm, responsible for the supervisory testing program, FINRA exam response, Reg BI implementation testing, written supervisory procedure maintenance, and the corrective action pipeline that feeds back into rep training and surveillance tuning. Sits between the CCO and the line analysts who run the day-to-day reviews. Owns the exhibit pack the examiner reads.

Who this is NOT for. Not for line compliance analysts who run individual reviews under direction, not for the CCO who signs the annual certification, not for IT staff building the surveillance tooling. This is for the senior manager who owns the testing program itself, builds the sampling logic, signs the WSP rewrite, and walks the examiner through the evidence binder.

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. Roughly eight to twelve hours of focused reading and template work across the twelve modules. The implementation playbook is the artefact the senior manager works from in parallel.

Why $199 is the right number

FINRA Institute and SIFMA seminars cover the rules but stop short of the testing program build. Big four advisory engagements deliver the program but at consulting rates and on the consultant's timeline. This course delivers the testing program build at a price point that lets the senior manager own the work and the artefacts directly.

FAQ

Does this cover the advisory side as well as the brokerage side?

Yes. Module 6 covers the SEC Marketing Rule testing program for the advisory arm. The Reg BI and FINRA Rule 3110 modules cover the brokerage side. The AML and books-and-records modules cover both.

Is the implementation playbook generic or specific to our exam findings?

Specific. The implementation playbook is hand-built using the firm's testing population, supervisory structure, and the obligations the most recent exam letter focused on.

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

The testing program design is independent of the vendor. The templates show how to layer firm-owned testing on top of vendor surveillance output, which is the layer examiners test most aggressively.

Does this assume a specific firm size?

The methodology scales from mid-size broker-dealers through the largest wealth platforms. The sampling logic adjusts by rep population and product complexity, which the implementation playbook tunes for the specific firm.

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.