ELEVATING YOUR CONFIDENCE

We concentrate on creating a required 3120 supervisory control system to ensure that the CEO can confidently sign the annual 3130 compliance certification.

We will draft, maintain, and test the Written Supervisory Procedures and obtain all necessary sub-certifications. We will review emails and conduct the annual Anti-Money Laundering Review. We will also manage individual licensing issues and ensure necessary CRD filings. We conduct the firm element training and the annual compliance meeting. We will also manage any SEC or FINRA exams with an on-site team. We will also ensure responses to any client complaints and maintain a complaint log, as required by FINRA. Perhaps most significantly, we will consult as requested on any broker-dealer compliance concerns facing our clients.

1

Chief Compliance Officer

We designate a member of our staff (acceptable to management) to serve as chief compliance officer. The CCO is responsible for administering the broker-dealer’s policies and procedures, reporting to management and staff, providing the annual written compliance report, and any other matters required of a CCO under FINRA rules.

2

Relationship Manager

We designate a member of our team to serve as your designated relationship manager (“RM”). The RM is responsible for delivering our services and ensuring that we meet your expectations.

3

New Member Application

We manage and/or assist with the NMA documentation and process.

4

Annual Review

We conduct the annual review of the adequacy and effectiveness of the policies and procedures as required by Rule 3120. The review includes a review of the policies and procedures, interviews of key personnel, obtaining certifications, reviewing internal and/or third-party compliance and internal control reports, reviewing cited regulatory deficiencies and/or exam results, noting observed risks, and testing implementation. We provide a detailed written report of our findings to management.

5

CEO Certification

We prepare, advise, and ensure completion of the annual CEO compliance certification including matters described therein.

6

Written Supervisory Procedures

We proactively draft, maintain and update the broker-dealer’s WSPs (including AML and BCP policies) to reflect regulatory changes and changes to the broker-dealer’s business. We draft all policies and work with management to include all recommended revisions and changes. We will monitor the industry and regulatory developments and recommend changes to policies and procedures as appropriate.

7

Compliance Calendar

We create, implement, and follow a detailed compliance calendar and project plan to ensure the timely completion of all compliance activities by all relevant parties.

8

Advice, Guidance and Support

We provide advice and guidance to management and staff with respect to any compliance and regulatory question.

9

AML Review

We conduct the annual Anti-Money Laundering Compliance review.

10

CRD/Licensing

We ensure the filing and recording of all forms related to securities licensing of employees.

11

Books and Records

We determine and advise on the documents required to establish and maintain FINRA-required books and records, including financial records, client files, and registered representative materials. We ensure that all relevant personnel and service providers receive and understand the compliance policies and procedures and obtain certifications with respect thereto.

12

Web CRD Filings

We prepare and file all routine Form BD amendments and registered representative filings (Form U4 and U5).

13

Compliance Committee

We convene and conduct quarterly meetings of an internal Compliance Committee composed of senior managers. The Compliance Committee addresses material compliance issues and discusses the compliance plan. We take and retain minutes.

14

Marketing Materials

We review marketing materials for FINRA compliance.

15

Email Review

We review emails as required by the policies and procedures.

16

Firm Element Training

We create an annual Needs Analysis and Training Plan. We design and conduct the Firm Element training program if requested.

17

Risk Assessment

We collaborate with management to conduct an annual risk assessment including an assessment of likelihood and impact of given business risks such as infrastructure, human resources, portfolio management, performance, expenses, and service providers.

18

Annual Compliance Meeting

We conduct the annual compliance meeting including creating the agenda, conducting the program, setting attendance requirements, maintaining attendance records, and following up.

19

Regulatory Exams

We manage regulatory exams conducted by FINRA and/or the SEC. This includes assembling materials in response to requests, interfacing with the exam staff, and preparing a written response to deficiencies.

20

Cybersecurity Assessment

We deploy our CyberSecure process (with Align Cybersecurity) to assess your cybersecurity policies and governance framework and your IT architecture, network and related technologies. The CyberSecure process also includes written recommendations and recommended policies.