DESIGNATION OF SUPERVISORS AND OFFICES
Date: ___________________                 Reviewed By: ____________________________...
GENERAL EMPLOYEE POLICIES
Date: ___________________                    Reviewed By: ______________________________________...
TRAINING AND EDUCATION
Date: ___________________                 Reviewed By: ____________________________________________...
EMPLOYMENT, REGISTRATION, AND LICENSING
Date: ___________________                  Reviewed By: __________________________...
SUBJECT                              RULE                    Tested By   Frequency of review   COMMENTS
                  ...
COMMUNICATIONS WITH THE PUBLIC
Date: ___________________                  Reviewed By: ___________________________________...
SUBJECT                              RULE                       Tested By   Frequency of review   COMMENTS
               ...
FINANCIAL AND OPERATIONS PROCEDURES
{Outside accountants may test some of these subjects if noted in “Comments”. Some area...
SUBJECT                             RULE                      Tested By   Frequency of review   COMMENTS
                 ...
SUBJECT                       RULE                  Tested By   Frequency of review   COMMENTS
                           ...
ANTI-MONEY LAUNDERING PROGRAM                                        Bank Secrecy Act; USA PATRIOT Act; FINRA 3011; MSRB R...
SUBJECT                            RULE                     Tested By   Frequency of review   COMMENTS
                   ...
INSIDER TRADING                  ’34 Act Sec. 10, Rule 10b-5; Insider Trading & Securities Fraud Enforcement Act of 1988; ...
ACCOUNTS
Date: ___________________                  Reviewed By: ______________________________________________

         ...
ORDERS
Date: ___________________                     Reviewed By: ______________________________________________

        ...
SUBJECT                               RULE                      Tested By   Frequency of review   COMMENTS
               ...
SUBJECT                          RULE                     Tested By   Frequency of review   COMMENTS
                     ...
SUPERVISORY CONTROLS                             FINRA 3010, 3012, 3130, NTM 04-71 and 04-79; MSRB Rule G-27

Date: ______...
OFFICES          FINRA 3010; NTM 86-65, 88-84, 89-34, 92-18, 04-71

Date: ___________________                   Reviewed B...
OTC EQUITY TRADING AND MARKET MAKING
Date: ___________________                    Reviewed By: ___________________________...
SUBJECT                           RULE                      Tested By   Frequency of review   COMMENTS
         (Sections ...
SUBJECT                            RULE                    Tested By   Frequency of review   COMMENTS
         (Sections i...
CORPORATE FIXED INCOME SALES AND TRADING
Date: ___________________                   Reviewed By: ________________________...
CORPORATE SECURITIES UNDERWRITING
Date: ___________________                   Reviewed By: _______________________________...
SUBJECT                                RULE                       Tested By   Frequency of review   COMMENTS
             ...
CORPORATE FINANCE
Date: ___________________                    Reviewed By: ______________________________________________...
MUTUAL FUNDS
Date: ___________________                   Reviewed By: ______________________________________________

    ...
OPTIONS            FINRA Rule 2860;

Date: ___________________                       Reviewed By: ________________________...
MUNICIPAL SECURITIES
Date: ___________________                    Reviewed By: ___________________________________________...
SUBJECT                             RULE                  Tested By   Frequency of review   COMMENTS
                     ...
SUBJECT                                 RULE                  Tested By   Frequency of review   COMMENTS
                 ...
GOVERNMENT SECURITIES                         Government Securities Act Amendments of 1993, Sections 102-107, SEC Rules 10...
COLLATERALIZED MORTGAGE OBLIGATIONS (CMOs)
Date: ___________________                      Reviewed By: ___________________...
FINANCING TRANSACTIONS
Date: ___________________                Reviewed By: _____________________________________________...
RESEARCH – EQUITY SECURITIES                                FINRA Rule 2711;

Date: ___________________                   ...
SUBJECT                               RULE                    Tested By   Frequency of review   COMMENTS
                 ...
DIRECT PARTICIPATION PROGRAMS (DPPs)                                   FINRA Rule 2810

Date: ___________________         ...
INVESTMENT ADVISERS
Date: ___________________                 Reviewed By: ______________________________________________
...
INDEPENDENT CONTRACTORS FINRA NTM 01-80, 99-95, 98-38, 86-65;
Date: ___________________               Reviewed By: _______...
PRIVATE PLACEMENTS AND OFFERINGS
Date: ___________________                   Reviewed By: ________________________________...
SOFT DOLLARS                [’34 Act, Section 28(e)]

Date: ___________________                   Reviewed By: ___________...
SUBJECT:
Date: ___________________   Reviewed By: ______________________________________________



           SUBJECT    ...
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Superv. Cont. Chk List

  1. 1. DESIGNATION OF SUPERVISORS AND OFFICES Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Designation of Supervisors and Supervisory FINRA Rule 3010(a) Duties For Each Supervisor (2) – (4) (Including branch supervisors.) [Are designations current? Are descriptions of areas of responsibilities accurate?] Designation of Executive Representative FINRA By-Laws Art. IV, Section 3, 1150 [Is the designation to FINRA current?] Designation of principal responsible for FINRA Rule 1140 supervision of form filings ] Assign each registered rep to a supervisor FINRA 3010(a)(5) and create a record of all reps supervised by each supervisor
  2. 2. GENERAL EMPLOYEE POLICIES Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Outside business activities FINRA Rule 3030; [Approval process; records retained] Private securities transactions – FINRA FINRA Rule 3040 [Approval process; books and records requirements if approval granted] Employee and employee-related accounts FINRA Rules 2010 & Rule 3010(d); • Review of transactions • Outside accounts FINRA Rule 3050 [Approval, monitoring] • Sharing in customer accounts FINRA Rule 2330(f) [Approval, monitoring] • Outside accounts FINRA Rule 3010(c), [Approval, monitoring] 3050(d);MSRB G-28 Charitable contributions FINRA Notice to Members 06-21; [Approval, records] Prohibited activities FINRA Rule 2370 • Borrowing from/lending to customers [Review of communications to identify] • Guarantees FINRA 2330(e); MSRB Rule G-251 [Review of communications to identify] Annual certification [Annual attestation re FINRA Guide to outside business activities; outside accounts; Written Supervisory private securities transactions; insider trading, Procedures etc.; obtaining, followup, records]
  3. 3. TRAINING AND EDUCATION Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Annual compliance meeting FINRA Rule 3010(a) (7) [Records of content, attendance, confirming requirement met by RRs] Continuing education FINRA Rule 1120; MSRB Rule G-3 [Developing annual firm element plan, controls to confirm employees complete required CE, restrict those who don’t] • Regulatory element • Firm element • Controls for persons who fail to complete requirements • Designating a CE contact person FINRA 1120(a)(7) MSRB apprentices MSRB Rule G-3 [Monitoring activities]
  4. 4. EMPLOYMENT, REGISTRATION, AND LICENSING Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Hiring procedures • CRD clearance for new hires [Process for checking CRD] • Background investigations conducted FINRA 3010(a)(6); 3010(e); MSRB G-7 • Obtaining fingerprints and flagging FINRA 1140(c)(2); responses SEC Rule 17f-2 Determining supervisors’ qualifications FINRA Rule 3010(a) [Process for determining newly-hired or (6); promoted supervisors are qualified by registration and experience] Termination procedures FINRA By-Laws [Filing required U-5s with CRD within 30 days Article V, Sections 2 and sending copies to RRs] and 3; Registration FINRA By-Laws Article V • Updating U-4s [Process for updating U-4s regarding reportable information] • Confirming all RRs are properly registered FINRA By-Laws, [At time of hire, when RR is transferred, when Article III, Section 2; RR expands business or location of accounts 1070; MSRB Rules (state registrations)] G-2 & 3; 1021; 1022; IM-1022-1; IM-1022-2; 1030; 1040; 1100; 1110 • Maintaining records of associated persons SEC Rule 17a-3(a) (12) • Parking of securities registrations FINRA By-Laws, [Avoiding registrations not required and held only Article III, Section 1; to avoid lapsing] Rule 1031(a) Statutory disqualifications ’34 Act Sec. 3(a)(39) [Hiring and supervision] & Rule 19h-1; FINRA By-Laws, Article III, Sections 3 & 4; Form MC-400; Rule 3070; MSRB Rules G-4 & G-5 • Screening for SD persons hired in clerical or ministerial positions • Supervision of SD persons
  5. 5. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Broker-dealer registration • Form BD FINRA By-Laws Art. [Current and filed on timely basis] IV, Section 1 • Regulatory contact information (FINRA) [Current?] Heightened supervision FINRA NTM 97-19, 03-49; • Identifying RRs for heightened supervision [Criteria current? Records of review?] • Records of heightened supervision [Memo to supervisor; records of reviews; supervisor certification]
  6. 6. COMMUNICATIONS WITH THE PUBLIC Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Advertising and sales literature FINRA Rule 2210, 2220; IM 2210-1; MSRB Rule G-21; SEC 17a3(a)(20) • Approval [Ads approved and records retained? Approved ads meet requirements?] • Inclusion of SIPC [SIPC included on all print ads?] • Filing requirements [Required material such as mutual fund ads filed with SROs?] Outgoing written correspondence SEC Rule 17a 4(b)(4); 17a(3)(20); FINRA 3010(d); • Review and approval • Fax reviews Incoming written correspondence • Review [Reviewed by designated person? Complaints referred to Compliance?] Institutional sales literature & FINRA Rule 2211 correspondence [Exceptions to usual review/approval requirements only for qualified accounts?] Complaints FINRA Rule 3110; MSRB Rules G-18(a) (xii) and G-10 • Review by principal • Copies to Compliance • Reporting to SROs FINRA Rule 3070; Customer privacy policies (Reg S-P) Regulation S-P • Provide initial, annual & revised privacy policy notices
  7. 7. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) • How & when policy is distributed to customers • Administrative, technical & physical safeguarding of information; testing of firewalls Scripts [Reviewed and approved? Records?] Calling restrictions Telephone Consumer Protection Act of 1991; Junk Fax Protection Act of 1995; FINRA Rule 2212 • Internal do-not-call list maintained and made available • Federal and state do-not-call information made available Public Speaking FINRA Rule 2210 [Approval process; records] Cold callers FINRA Rule 2210, [Approved callers and scripts] 2212,3010(b) (2),3110(g) Electronic communications • Systems and devices approved • Education of employees • Opt-out procedures • Instant messaging ban or review of permitted access • Review of communications [Training for reviewers; identity of items requiring prior approval; records of review] • Retention of records in retrievable format • Firm web site FINRA Taping Rule FINRA Rule 3010(b)(2); [Compliance with requirements to determine % of tapes to review, designate person to review, record reviews and retain records] [Only applies to firms designated by FINRA as subject to the Taping Rule.]
  8. 8. FINANCIAL AND OPERATIONS PROCEDURES {Outside accountants may test some of these subjects if noted in “Comments”. Some areas may be the responsibility of a clearing firm, if so noted} Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Books and records SEC Rules 17a-3 & 17a-4; FINRA 3110; MSRB G-8 and G-9 • Main office records • Branch records [Required records retained in branches?] • Clearing firm records [Is it clear re what records to be retained by clearing firm?] • Electronic storage of records SEC Rule 17a-4(f) [Consistent with requirements?] Calculation and reporting of net capital SEC Rules 15c3-1, 17a-11; FINRA NTM [Timely filings, accuracy] 92-72, 93-30, 99-44 Reconciliations and bank records [Reconciliations done, records retained] Financial reporting SEC Rules 17a-5 & 17a-11; FINRA Rule [Financial statements sent to customers] 2270 • Part-time FINOP (if applicable) FINRA NTM 06-23] [Meet regulatory requirements? Reg T and extension of margin Regulation T; FINRA [Calculation of requirements, notification, Rule 2520 sellouts when required] Fees and service charges FINRA Rule 2430; [Customer notification at time account opened; at least 30 days before changes; on web site] Fidelity bonding FINRA Rule 3020; [Current?] Risk Management FINRA NTM 99-92; [Establishment of department or committee, reviews, records]
  9. 9. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) New products FINRA NTM 05-26 [Review and approval, records] Business continuity plan FINRA 3510, 3520; • Identify Emergency Contact Persons NTM 04-37 • Address data back-up and recovery • Address mission critical systems • Address periodic assessment of financial and operational risks • Address alternate communications during emergency • Address providing an alternate physical location for employees • Address the impact of disruption upon critical counterparts • Address regulatory reporting and communications with regulators • Provide for customers’ prompt access to funds and securities in the event that firm is unable to continue its business • Address disclosure requirements of Rule 3510 • Address the requirements for updating, annual review, and senior management approval provisions Customer payments for purchases [Checks payable to clearing firm, if required] Transmittals of customer funds and FINRA Rule 3012(a) securities (2)(B); [Branch safeguarding of checks; transmittals to third parties or an alternate address] • Deliveries by RRs to customers [Approval, records] Safekeeping of customer funds and SEC Rule securities (Customer protection) 15c3-3;17a-13; • Reserve computations 8c-1; 15c-1; 15c3-3; 17a-13. FINRA • Quarterly box count Rules 2330 & 3140; • Safekeeping and segregation of customer MSRB Rule G-25 securities Customer confirmations and statements SEC Rules 10b-10, 17a-3; FINRA Rule 2320, 2830; IM 2230; MSRB Rule G-15 • Control of blank confirms and statements • Customer address changes – sending FINRA Rule 3012(a) confirmation (2)(B); • Hold mail procedures FINRA Rule 3110(i);
  10. 10. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) • Required disclosures on confirmations Annual disclosure of FINRA BrokerCheck FINRA Rule 2280 Clearing agreements FINRA Rule 3230; [Records] Short interest report FINRA Rule 4560 [Records, timely filing] Regulatory fees & assessments FINRA By-Laws, [Responsibility, payment] Schedule A; MSRB Rules A-13 and A-14 Outsourcing FINRA NTM 05-48; [Review, monitoring of services, records]
  11. 11. ANTI-MONEY LAUNDERING PROGRAM Bank Secrecy Act; USA PATRIOT Act; FINRA 3011; MSRB Rule G-41 NOTE: This entire section may be covered by the required independent testing, and if so, this is noted at the beginning of this section without further notations on the subjects included here. Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Designation of AML Compliance Officer FINRA Rule 3011(d), IM-3011-2 Independent testing FINRA Rule 3011(c), [Conduct of independent testing of AML IM-3011-1; procedures, meeting requirements for independent tester] Education of employees OFAC list and blocked property Dept. of Treasury [Accounts checked; accounts blocked if statutes; OFAC web necessary] site including lists of blocked persons/entities Currency reporting requirements SEC Rule 17a-8; • Identify cash transactions for filing CTRs Bank Secrecy Act • Verify the identity of customers for filing CTRs • Filing CTRs Recordkeeping requirements • Fund transfers and transmittals Bank Secrecy Act 31 CFR Part 103; FINRA NTM 97-13, 96-67 & 95-69 Information sharing between financial USA PATRIOT Act, institutions Section 314; Bank Secrecy Act • Annual FinCEN certification • Verification that institutions with whom information is shared have filed their certification Suspicious Activity Reports (SARs) SEC Rule 17a-8; [Review of potential suspicious activities; filing USA PATRIOT Act reports; records] Sec. 356; FINRA NTM 89-12, 97-13, 02-47 Requests and written notices from USA PATRIOT Act, enforcement agencies section 314, and
  12. 12. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) [Responses to agency requests; records] Bank Secrecy Act Customer identification program (CIP) USA Patriot Act Sec. [Obtaining required customer information, 326 records] Due diligence for correspondent and private USA PATRIOT Act banking accounts Secs. 312 & 313 [Identifying accounts for extra due diligence; Compliance approval where required; monitoring accounts; bank certifications] Shell companies [identifying accounts, obtaining information, approval]
  13. 13. INSIDER TRADING ’34 Act Sec. 10, Rule 10b-5; Insider Trading & Securities Fraud Enforcement Act of 1988; FINRA NTM 89-5; Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Annual certification Employee, employee-related and proprietary trading [Reviews, records of reviews and action taken] Information barrier procedures [Current and adequate reflecting Firm’s current businesses? How monitored and enforced? Education of employees?] Watch list [Maintaining list, adding companies, monitoring, actions taken] Restricted list [Maintaining list, adding companies, monitoring, actions taken]
  14. 14. ACCOUNTS Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) New accounts SEC Rule 17a-3(a)- (17); FINRA Rules 2310 & 3110(c); MSRB Rule G-8 • Approval SEC Rule 17a-3(17)(i) (A); FINRA Rules 2310(b) and 3110(c); • Accounts for employees of other BDs FINRA Rule 3010(c) [Notification to and approval from other BD, (2)(C) & 3050; MSRB copies to other BD] Rule G-28 • Accounts for employees of FINRA and FINRA Rule 2070 AMEX [Notification, approval] • SIPC disclosure at time of account opening FINRA Rule 2342; and annually Customer account information '34 Act Rule [Copy to customer at time of opening for 17a-3(17)(i)(A); affirmation and periodic affirmation] FINRA Rule 3012(a) (2)(B); Transferring accounts FINRA Rule 11870; [Timely processing] Account documents [Controls for obtaining required documents and follow up of deficiencies] ] Margin accounts [Approval of accounts; providing disclosure to customers] Third party accounts SEC Rule 17a-4(b)(6) [Obtaining necessary authorizations] Discretionary accounts FINRA Rule 2510, [Requires investment adviser registration for the 3110(c)(3); MSRB Firm; approval and review of accounts] Rule G-19 Day trading accounts [FINRA Rule 2360] [Risk disclosures, approval, monitoring] Active accounts [Reviews] Concentrations [Reviews]
  15. 15. ORDERS Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Orders requiring approval [Types of orders that must be approved prior to entry; current in WSP?] Suitability of recommendations FINRA Rules 2010, [Are reviews being conducted to determine 2310, 3110(a); suitability? Does the Firm have special FINRA Rules requirements for certain products and, if so, are 2720(k) –self those requirements fulfilled?] underwritings; 2810(b)(2-DPPs; 2353 - index warrants; 2360(b) (19) – options; NTM 96-86-Variable Annuities; MSRB Rule G-19 Fair prices Regulation NMS; [Processes for determining fairness of markups/ FINRA Rules 2320, markdowns, agency commissions] IM-2320 & 2400; MSRB Rules G-17, G-18, & G-30] • Best execution [conducting reviews. records of reviews, actions taken] • Regulation NMS [Identifying trade-throughs; handling intermarket sweep orders; using third-parties to comply] • Trading ahead of customers (“frontrunning”) FINRA Rule 2111, IM-2110-2 [Controls to identify frontrunning] Account Designation and Cancels/Rebills FINRA Rule 3110(j); [Controls for identifying, approving changes in accounts on orders] Trade Reporting By Third Parties FINRA Rules 4630, [Processes for confirming third parties are 6000C, 7220A & reporting trades as required] 7320, 6200, 6400 and
  16. 16. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) 6641 Trading systems and electronic transmission FINRA Notice to of orders Members 04-66; • Customer Access To NASDAQ Order Entry FINRA NTM 98-66 Systems [Written agreements, notifying NASDAQ, monitoring] Order records '34 Act Rules 17a-3  [Confirming required records are retained] 17a-4; FINRA Rule 3110; Conflicts of interest [Customer orders/fair prices compared to employee/firm trading] • Secondary Market Transactions In The '34 Act Rule 17h-1T; Firm's And Its Affiliates' Securities [Restrictions on recommending the Firm’s or an affiliates’ securities] Review of transactions SEC Rules 10b-5, [Processes for reviewing customer transactions 15c1-7; FINRA for compliance with rules] Rules 2010, 2020, 2130, 3010, IM-2110-1 & IM-2440; MSRB Rule G-27(c) Trade errors [Processing errors, control & monitoring of error accounts] Time clock synchronization FINRA Rule 7430 [Procedures to ensure time clocks are accurate] Blue sky of securities [Various state blue [Procedures to confirm solicited purchases of sky requirements] unlisted securities meet blue sky requirements] Certificates of deposit FINRA Notice to [Necessary disclosures when selling to Members 02-69; customers] REITs [Reviews for suitability] Hedge funds FINRA NTM 03-07 [Due diligence, suitability; review of subscription agreements; training of RRs Structured products FINRA NTM 05-59] [Due diligence; use of promotional materials; account eligibility; suitability; training of RRs] Short sales Regulation SHO
  17. 17. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) [Marking orders; locate and delivery requirements] Sales of control or restricted stock SEC Rules 144 & 145 [Filing and trading requirements] Penny stocks SEC Rules 15g(1)- (designated securities) (9), 15g1-100, 3a51-1; FINRA NTM, 92-38, 92-42, 93-55 • Risk disclosure statement provided to customers [2-day waiting period observed] • Suitability • Confirmation disclosures Payment for order flow '34 Act Rule 10b-10, [Written agreements; confirmation disclosures; Regulation NMS Rule new account and annual disclosures] 607 Orders of behalf of a foreign BD SEC Rule 15a-6 [Determining BD not disqualified; written consent; Firm’s responsibilities] FINRA Order Audit Trail System (OATS) FINRA 6950 series • Daily Clock Synchronization • Review of OATS data to confirm compliance Disclosure of order execution procedures Regulation NMS, [Verify reports published] Rule 605 Order routing and reporting Regulation NMS, [Verify reports published] Rule 606 Cash and non-cash compensation policy FINRA 5110, 2810, [Verify compliance with requirements for any 2820, 2830; NTM arrangements] 95-55, 95-56, 95-75 Prohibited transactions and practices SEC Rules 10b-5, [Verify reviews in place] 15c3-1 FINRA Rule 2010 • Unauthorized trading FINRA IM-2310-2; • Parking securities • Churning FINRA IM-2310-2; • Frontrunning FINRA Rule 3380;
  18. 18. SUPERVISORY CONTROLS FINRA 3010, 3012, 3130, NTM 04-71 and 04-79; MSRB Rule G-27 Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Small firm with limited size and resources [If applicable, establishing exception] Written supervisory procedures FINRA Rule 3012(a) [Verifying procedures are current and reflect (1); MSRB Rule Firm’s businesses] G-27(c) • Distribution of procedures and amendments FINRA Rule 3010(b) (4) Chief compliance officer FINRA Rule 3130; [Designation] Annual compliance report to CEO FINRA Rule 3012(a) (1) FINRA Rule 3130, IM-3013; • FINRA report [Verify filing] • CEO annual certification FINRA Rule 3130(b) Supervision of producing managers’ FINRA Rule 3012(a) customer account activity (2)(A) [Limited size exception, if applicable; identifying producing managers, assigning supervision, reviews conducted]
  19. 19. OFFICES FINRA 3010; NTM 86-65, 88-84, 89-34, 92-18, 04-71 Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Office designations FINRA By-Laws NOTE: List of offices appears in chapter [Are offices properly designated?] Article IV Section 8, DESIGNATION OF SUPERVISORS AND OFFICES. Rule 3010; Non-branch locations FINRA Rule 3010(c), [Approval of persons to operate there; IM-3110-1, NTM supervision] 86-65, 04-71; Supervision of producing managers FINRA Rule 3012; [Is supervision being conducted? Is there followup when there are problems?] New offices or changes in existing offices FINRA By-Laws [Form BR filings made?] Article IV Sec. 8; Use of office space by others [Do any arrangements exist? If yes, were they approved?] Office records SEC Rules 17a-3 and [Are required records retained in branches?] 17a-4 Office inspections FINRA Rule 3010(c) [Are office inspections scheduled, conducted, (1 reports issued?] • Limited size exception FINRA Rule 3010(c) [Applies?] (3) • Heightened inspections of non-branch locations and other offices [Are offices identified for possible heightened inspections? Are non-branches reviewed?] Branch manager’s checklist [Are checklists being submitted?] Display of membership certificates [Are required certificates displayed in branches?] Availability of rules [Are rules available in branches?] Offices on bank or other financial institution FINRA Rule 2350; premises NTM 94-47, 94-94, [Are bank premises requirements reviewed? Is 95-49, 97-26, 97-89 there compliance?]
  20. 20. OTC EQUITY TRADING AND MARKET MAKING Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Registration of traders FINRA Rule 1022, NTM 00-46 Initial market making requirements (15c2-11) SEC Rule 15c2-11; [Making required filings prior to initiating quotes FINRA Rule 6440 in NNOTC securities] Quotations ; NASDAQ Rule 4613 [Testing compliance with quotation requirements] • Dissemination of quotations Regulation NMS [Disseminating CQS quotes only if registered as Rule 602 a CQS market maker; if sole quote for an NMS stock, provide data to an information processor] • Firm quotes FINRA Rule 6170(b) • Backing away FINRA Rule 3320, IM-3320; NASDAQ Rule 3320 • Withdrawal of quotes NASDAQ Rule 4620 • Locked and crossed markets NASDAQ Rule 4613(e) Fair prices/Best execution Regulation NMS • Best execution FINRA Rule 2320; [Testing for best execution; documenting NASDAQ Rule 2320; quotations for NNOTC transactions] MSRB Rule G-18 • Regulation NMS Regulation NMS Rule [Testing trade-through compliance, handling 611 intermarket sweep orders (ISOs), testing compliance by conduits/third party vendors that handle orders] • Fair pricing FINRA Rule 2440, [Testing for compliance with fair IM-2440 markups/markdowns, fair agency commissions, use of contemporaneous cost for dominated/controlled markets] • Market orders FINRA Rule 2111; [Testing for trading ahead of customer market NASDAQ Rule 2111 orders] Limit orders Regulation NMS Rule [Testing for compliance with display 604; FINRA requirements, best execution] IM-2010-2, Rule 2111; NASDAQ IM-2110-2
  21. 21. SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Short sales Regulation SHO [Marking orders, locate and delivery requirements] Trading halts FINRA Rules 3340, [Compliance with trading halts] 6120 & 6460; NASDAQ Rules 4120, 4121, & 6430 CQS securities Regulation NMS [Reporting transactions, compliance with Rules 600(b)(73)(ii), quotation requirements, compliance with 1% 601 & 602; FINRA rule) Rule 4632 ADF FINRA Rule 6320A • Certification FINRA Rule 4200A(5) [Filed annual certification with FINRA?] & 4300A • Registration as market maker FINRA Rule 4611A • Access requirements Regulation NMS Rule 610; FINRA Rule 4300A • Quotation requirements Regulation NMS Rules 600(b)(3) & (37); FINRA Rule 4613A • Locking and crossing FINRA Rule 4130A • Withdrawal of quotations FINRA Rule 4619A • Trade reporting FINRA Rules 4630A, [Compliance with reporting requirements] 7320A, 4720, 5430  6380A • System outages FINRA Rule 4300A(f) [Reported to FINRA and trades reported next day?] Other requirements • Schedule 13G reports SEC Rules 13d-1 & 13d-2 [Filed if required?] • Authorized use of NASDAQ workstations [Access only to authorized persons, use of passwords] • Errors FINRA Rule 11890; [Control of error accounts, following clearly NASDAQ Rule 11890 erroneous transaction procedures] • System outages [Reporting internal system outages to FINRA] Distributions of securities Regulation M • Passive market making [Compliance with passive market making when engaged in distribution] • Stabilizing bids NASDAQ Rule 4614 Trade reporting FINRA Rules 4632, [Testing for accurate trade reporting] 7220, 7240, 7320,
  22. 22. SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) 7330, 7340, 6400, 6550, and 6622 • Reporting trades to ACT • Riskless principal transactions FINRA Rule 4632(d) (3)(B) • Trade reporting by third parties [Testing for third party’s compliance] Other reports • Short interest report FINRA Rule 4560; [Timely filings?] NTM 03-08 • Disclosure of order executions Regulation NMS Rule [Data published?] 605 Clock synchronization FINRA Rule 7430; [Daily checking, records] Cell phones and PDAs [Limited to authorized use?] Prohibited activities • Anti-competitive and antitrust activities SEC 21(a) report; FIINRA IM-2110-5; NASDAQ IM-2110-5 • Trading ahead of research FINRA 2110-4; NASDAQ 2110-4 Books and records SEC Rule 17a-3(a); FINRA Rule 3110
  23. 23. CORPORATE FIXED INCOME SALES AND TRADING Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Fair prices FINRA Rule2440, [Test for fair markups/markdowns and agency IM-2440-1 commissions] • Markups/markdowns • Commissions on agency transactions Errors [Controls for error accounts] Cancels and rebills FINRA Rule 3110(d) [Changes in account designations approved?] Extended settlements; delayed deliveries FINRA Rule 11320 [Supervisor reviews, identifying patterns] Traders’ personal accounts [Compliance with personal trading policy] TRACE FINRA Rule 6200 [Testing for compliance with reporting rules] Procedures for clock synchronization FINRA Rule 6953 [Daily testing, records] Prohibited activities • Frontrunning (research, trades) FINRA IM-2110-3 • Adjusted trading SEC Rule 10b-5 Review of transactions FINRA Rule 3010 [Required reviews conducted?] High yield debt securities [Suitability, research]
  24. 24. CORPORATE SECURITIES UNDERWRITING Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Deal file [Files established and maintained?] Managing underwriter responsibilities • Due diligence SEC Rule 10g-5; FINRA Rules 2310 & 2810 • Underwriting compensation FINRA Rule 5110) [Reviews for compliance with rule] • Prospectuses '33 Act Secs 2(a) [Preparation, distribution, records] (10), 10-12; Rules 154, 174, 434  460; '34 Act Rule 15c2-8; Reg C, Rule 421 • Regulatory filings FINRA Rule 5110, 5190, 2740, 6540, & 6760(b); • Road shows [Records; compliance with requirements for video and internet shows] Aftermarket activities Regulation M, Rules [Stabilizing, penalty bids, syndicate covering] 100 & SEC Rule 17a-2; FINRA Rules 4614, 4624, 4625  5106; • Settlement of syndicate accounts FINRA Rule 11880 [Records, timely settlement] • Payments of concessions, discounts, FINRA Rule 2740 allowances [Paid only to registered BDs?] • Designated orders [Records?] Syndicate member procedures [Tombstone ads, issuing research during distribution] Selling group member procedures [Tombstone ads, issuing research during distribution] Communications around the time of '34 Act Section 5(a), registered offerings Rules 134, 135, 163, [Test compliance] 163A, 164, 168, 169  433, Release No.
  25. 25. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) 34-52056 Sales to the public [Records of indications of interest; preliminary and final prospectuses provided] Restrictions on purchases and sales of FINRA Rule 5130 equity IPOs [Are restricted persons identified and precluded from buying IPOs? Certifications on file for non- restricted persons?] Trading restrictions while participating in a Regulation M; FINRA distribution Rule 5190 [Securities added to restricted lists and violating trades identified and action taken? Short sales] Intrastate offerings '33 Act Sec. 3(a)(11), [Issuers and purchasers qualified?] SEC Rule 147 Regulation S offerings Regulation S [Sold only to qualified purchasers?] Eurobond and foreign sovereign debt offerings [Purchasers qualified and sales suitable?] Regulation A offerings Regulation A [Are issuers qualified?] Best efforts underwritings SEC Rules 15c2-4 & [Escrow requirements, closing the deal] 10b-9 Offerings of the Firm’s or affiliate’s securities '34 Act Rules 15c1-5  [Participation by the Firm, independent 15c1-6; FINRA Rule underwriter requirements] 2720 Prohibited activities '34 Act Rule 15c1-3; [Tying, laddering, quid pro quo, spinning, FINRA Rule 2760 misrepresenting pricing]
  26. 26. CORPORATE FINANCE Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Engagements [Investment committee approval] Confidentiality [Information barrier procedures followed?] Regulation FD [Personnel aware of requirements?] Fairness opinions FINRA Rule 5150 [Disclosures included, approval of opinions] Personal trading of corporate finance personnel [Compliance with personal trading policies] Recordkeeping [Records of banking deals] Adding engagements to the Firm’s Watch or Restricted List [Compliance notified to add deals to lists?]
  27. 27. MUTUAL FUNDS Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Mutual funds offered by the Firm [Dealer agreements] Sales charges FINRA Rule 2830(d) [Breakpoints monitored, LOIs, ROA observed] • Deferred sales charges FINRA Rule 2830(n) [Confirmation legends] Switching FINRA NTM 92016 & [Letters obtained?] 91-39 Market timing transactions FINRA Notice to [Recommended? Limited to one family of Members 95-80 funds?] Reinvestment of maturing CDs into mutual FINRA NTM 93-87 funds [Disclosures made to customers?] Suitability FINRA NTM 07-36 & [Review for suitable classes sold, reviewing 07-06 mutual fund investments of customers of newly- hired RRs and transfers to new funds] Late trading and market timing FINRA NTM 03-50 [Reviews to identify prohibited activity] Block letter restrictions [Compliance with blocking letters] Correspondence FINRA Rule 2210 [Review, accompanied by prospectus] Seminars and other public presentations [Approved by supervisor, records] Sales contests and incentive programs [Approval by Compliance] Prompt transmission of applications and FINRA Rule 2830(m) payments [Same-day transmission by RRs]
  28. 28. OPTIONS FINRA Rule 2860; Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Opening option accounts FINRA Rule 2360; [Option agreements obtained, approved, providing disclosure document] Option orders FINRA Rule 2360 [Trading within approved levels; suitability] Disclosure of option order routing Regulation NMS Rule [Reports published?] 605 Reporting options positions FINRA Rule 2360 Position Limits / Exercise Limits FINRA Rule 2360 Branch copies of statements FINRA Rule 2360 [6 months retained in branches) Option complaints [Central option complaint file]
  29. 29. MUNICIPAL SECURITIES Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Administration and operations • Apprentices MSRB Rule G-3 [Observing 90-day period] • Registration of principals MSRB Rule G-3 [All municipal supervisors are properly registered] • Control relationships MSRB Rule G-22 [Disclosures] • Electronic mail contact MSRB Rule G-40 [Contact filed with MSRB and current?] Bank dealers MSRB Rule G-1 [Separately identifiable department; referrals from non-registered bank employees; supervision] Sales of municipal securities • Suitability MSRB Rule G-19 [Reviews, supervision] • Required disclosures SEC Rule 15c2-12 [Checks for material events, disclosure] • Review of customer accounts • Complaints MSRB Rules G-10 & [Review and response, providing investor G-17 brochure] • MSRB rules MSRB Rule G-29 [Availability of rules in each office conducting municipal transactions] College savings plans (Municipal Fund FINRA NTM 03-17 Securities) • Registration [Principals, RRs] • Disclosures [Official statements/program disclosure documents provided?] • Suitability Reviews conducted for out-of-state plans, investment objectives vs. underlying investments?] • Advertising SEC Rule 482; MSRB [Approvals obtained?] Rule G-21(e) Sponsoring meetings and conferences MSRB Notice involving issuer officials 2007-13 [Review & approval, letter to sponsor]
  30. 30. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Advertising and sales literature MSRB Rule G-21 [Compliance with requirements, review & approval] Underwriting • Disclosures SEC Rule 15c2-12 • CUSIP numbers MSRB Rule G-34 • Expenses MSRB Rules G-17 & [Reasonableness] G-20 • New issue dales during underwriting period MSRB Rule G-11 • Contingency offerings SEC Rules 10b-9 & [escrow account, closing the deal] 15c2-4 • Records MSRB Rules G-8 & G-9 • Official statements MSRB Rule G-32 [Providing statements to dealers, purchasers, others] • Filings of OSs and advance refunding MSRB Rule G-36 documents with MSRB Financial advisor activities MSRB Rule G-32 • Registration requirements • Written agreements • Underwriting activities [Terminating financial advisor relationship, disclosures to issuer and purchasers, remarketing activities] • Records MSRB Rules G-7 & G-8 Solicitation of municipal securities business MSRB Rule G-38 [No prohibited payments to affiliated persons] Trading and handling customer orders • Quotations MSRB Rule G-13 • Fair prices MSRB Rule G-30 [Prices reasonable, markups/markdowns, agency commissions] • Records of orders MSRB Rule G-8 • Reports of transactions MSRB Rule G-14 [Orders reported as required] • Errors [Reviews, prompt corrections] • Cancels & rebills [Review & approval of changes in account designations]
  31. 31. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) • Traders’ personal accounts [Compliance with personal trading policy, reviews] Prohibited activities • Parking securities • Adjusted trading Gifts MSRB Rule G-20 [Review and approval, records] • Sales contests MSRB Rule G-20.20 [Written agreement with sponsors, review & approval] Political contributions MSRB Rule G-37 • Review & approval • Look-back/look-ahead [Identifying employees’ prior contributions that subject Firm to restrictions; imposing restrictions] • PACs [Firm/affiliates’ PACs comply with limitations] • Records • Quarterly report to MSRB [Filed?} • Business restricted, if required because of contributions?
  32. 32. GOVERNMENT SECURITIES Government Securities Act Amendments of 1993, Sections 102-107, SEC Rules 10b-5, 17a-3; FINRA NTM 95-48, 96-66 Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Government Sponsored Enterprise (GSE) distributions • Delivery of offering materials • Prospectuses • Master agreements • Single class TBAs [Disclosures on confirmations] Sales and trading • Suitability • Fair prices [Markups/markdowns, agency commissions] • Traders’ personal accounts [Compliance with personal trading policies, review] • Review of transactions [Reviews conducted? Reviews done for potential prohibited activities?] Transaction records Government Securities Act Amendments of 1993 Section 103 Large position reporting Government Securities Act Amendments of 1993 Section 104
  33. 33. COLLATERALIZED MORTGAGE OBLIGATIONS (CMOs) Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Suitability FINRA IM 2110-8(b) [Reviews, disclosures to customers] (2) Required education material FINRA IM-2210-8(b) [Prior to sales to retail customers, provide (2) brochure] Inverse floaters, IOs, POs [Suitability, reviews] Communications with the public FINRA IM-2110-8 [Compliance with requirements, review & approval] Trading • Fair prices FINRA Rule 2440, [markups/markdowns, agency commissions] IM-2440 • Errors [Control of account] • Cancels & rebills [Review & approval of changes to account designations] • Traders’ personal accounts [Compliance with personal trading policies, review] Confirmations SEC Rule 10b-10 [Disclosures]
  34. 34. FINANCING TRANSACTIONS Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Repurchase and reverse repurchase SEC Rules 15c3-1, transactions 15c3-3(b)(4) • Written agreements • Hold-in-custody repurchase transactions • Confirmations • Collateral [Review and approval • Deficits and margin calls • Mark to market • Dollar rolls • Order records • Repurchase transaction rates [Changes in rates recorded] • Credit approval Bonds borrowed and loaned transactions SEC Rule 15c3-3(b) (3) • Agreements • Collateral • Mark to market • Credit approval
  35. 35. RESEARCH – EQUITY SECURITIES FINRA Rule 2711; Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Registration and supervision of research FINRA Rule 1050; analysts [Qualification of analysts and supervisors] Continuing education FINRA Rule 1120; Research analyst compensation FINRA Rule 2711(d) [Limitations, approval] Confidentiality of research activities [Maintain confidentiality of research reports prior to publication] Information barriers FINRA IM-2110-4 [Limits on communications between departments] Regulation FD Regulation FD [Personnel knowledgeable of requirements?] Standards for research reports FINRA Rule 2210 Disclosures and statements FINRA Rule 2711(h)) [Required disclosures on research reports] • Analyst certifications Regulation AC • Third party research FINRA Rule 2711(h) (13) Public appearances of research analysts • Approval • Disclosures FINRA Rule 4711(h) Communications regarding investment FINRA Rule 4711(c) banking services (5) [Compliance with limitations, Compliance Dept. as go-between and records of communications, prohibition against analyst participation in roadshows] Blue sky of securities recommended Various state blue sky [Determining blue sky status of unlisted requirements securities in recommendations; legends added if needed] Review of research reports
  36. 36. SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) • Small firm exemption FINRA Rule 2711(k)) [If applicable, determining qualification and compliance with requirements] • Subject company communications FINRA Rule 2711(c); [Limitations] • Approval of reports • Retention of reports and backup materials Quiet periods affecting research reports and FINRA Rule 2711(f); public appearances • Quiet period [Observance of restrictions on issuing reports] • One-day restriction [Imposition of internal restriction against acting on recommendations] • Watch or restricted list additions [Notifying Compliance; adding security to lists to impose one-day restriction] • Monitoring restrictions Termination of coverage FINRA Rule 2711(f) [Final report issued] (5); Personal trading of research analysts FINRA Rule 2711(g); [Compliance with personal trading policies; ) review] Prohibitions • Soliciting investment banking business • Changing inventory positions in advance of research report • Frontrunning a research report [Reviews to identify, actions taken] Annual attestation of research supervisory FINRA Rule 2711(i); procedures [Required attestations filed annually]
  37. 37. DIRECT PARTICIPATION PROGRAMS (DPPs) FINRA Rule 2810 Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) New issues FINRA Notices to Members 04-50, 04-07  95-63 • Due diligence • Investment committee approval • Suitability FINRA Rule 2310 [Establishing standards, determining purchasers are qualified]] • Subscription agreements [Obtaining, reviewing] • Prospectuses • Disclosures FINRA Rule 2810(b) (3) Rollups FINRA Rule 2810(b) [{Agreement with general partner; disclosure (6) & NTM 94-70 letter to limited partners] Secondary market transactions FINRA NTM 91-69 • Trade records • Reporting transactions FINRA Rule 6920 • Standard transfer forms FINRA NTM 96-14 [Obtaining forms when necessary]
  38. 38. INVESTMENT ADVISERS Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Investment adviser activities must be authorized [Only authorized RRs engage in IA activities] Recommending investment advisers [RRs must recommend IAs from Firm list of approved IAs] Registration requirements [Firm required to register as an IA?] • Fee-sharing arrangements Wrap fee programs • Firm list of eligible IAs • Fairness of fees • Written agreements on file for customers • Disclosure document provided to customers • Periodic reports provided to customers • Reviewing wrap fee accounts • Communications regarding performance include effect of fees Adviser compensation arrangements [Included in customer agreements]
  39. 39. INDEPENDENT CONTRACTORS FINRA NTM 01-80, 99-95, 98-38, 86-65; Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS (Sections in WSP Manual) N/A REFERENCE(S) Supervision [Records of IC supervision] Agreements [Written agreements with RRs] Use and display of the Firm’s name [Proper use by ICs] Display of SIPC symbol [Displayed by IC?] Use of other names [Approvals on file?] ICs as investment advisers FINRA Rule 3040, [Approved? Supervision?] Notices to Members 96-33, 94-44  91-32 Exempt insurance products and equity- FINRA NTM 05-50 indexed annuities [Approval from Compliance]
  40. 40. PRIVATE PLACEMENTS AND OFFERINGS Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Blue sky requirements [Procedures followed to verify blue sky status] The Firm’s participation in private placements [Agreement with issuer, due diligence, integration issues, Form D] Sales of private placements [Suitability, purchaser questionnaires, offering memorandum, subscription agreements] • Contingency offerings '34 Act Rules 15c2-4  [Escrow account, closing the deal] 10b-9 • 1031 tax-deferred exchanges Section 1031 of the Internal Revenue Code, IRS Revenue Procedure 2002-22; FINRA Notice to Members 05-18 Internet offerings [Qualifying purchasers, disclaimers and other information on the web] Rule 144A transactions SEC Rule 144A [Determine QIB qualifications, disclosure letter] Private investment in public equity (PIPE) [determine accredited status of investor, disclosures]
  41. 41. SOFT DOLLARS [’34 Act, Section 28(e)] Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S) Agency and riskless principal transactions [Principal transaction not allowed?] Research services [Only allowed services included in arrangement] Brokerage services [Only allowed services included in arrangement] Broker-dealer obligations [Compliance with requirements, letter to adviser] Third party services [Only qualifying services provided, review and approval] Commission-sharing arrangements [Comply with requirements] Approval of soft dollar arrangements [Approval, maintain list of arrangements] Statements [Annual statement to IA re services provided and commitment to pay soft dollars] Review of accounts
  42. 42. SUBJECT: Date: ___________________ Reviewed By: ______________________________________________ SUBJECT RULE Tested By Frequency of review COMMENTS N/A REFERENCE(S)

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