AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.

AML Audits

FINRA Rule 3310 requires every broker dealer to conduct an independent Anti Money Laundering Audit. Our staff of highly trained consultants can perform your AML audit and provide your firm with a professional written report identifying areas of compliance weakness, as well as suggestions on how to improve your internal compliance systems.

For more information about our AML audit services, please contact us at (877) 542-6759.

 

Comprehensive Compliance Services

Thornton & Associates, LLC can customize a Comprehensive Compliance Package to assist your Compliance Department in meeting your regulatory obligations.  Below is a list of services that can be included in your Compliance Package.

Please contact us at (877) 542-6759 for more information about our Comprehensive Compliance Packages.

Annual Reviews and Internal Audits

  • Conduct a comprehensive FINRA Rule 3010 Internal Audit
  • Complete the annual SEC Rule 17(a)(4) Electronic Storage Audit
  • Conduct the annual Regulation SP Privacy Policy Audit
  • Complete the annual Business Continuity Plan review.
  • Update the firm’s OSJ and branch office audit program.
  • Assist in the completion of the FINRA Rule 3120/3130 Supervisory Systems Audit
  • Moderate the annual CEO/CCO 3120/3130 meeting
  • Prepare the annual CEO Rule 3120/3130 Compliance Program Certification

Anti Money Laundering

  • Conduct an Independent Anti Money Laundering Audit
  • Conduct the firm’s Anti Money Laundering Training
  • Revise and update the firm’s Anti Money Laundering Procedures
  • Review and update the firm’s Customer Identification Program
  • Prepare and review the annual CEO Anti Money Laundering Program Certification
  • Assist in filing SAR’s if needed

Continuing Education

  • Prepare the annual Needs Analysis
  • Prepare the annual Training Plan
  • Coordinate and monitor the firm’s online continuing education completion progress
  • Update the firm’s Regulatory Element Plan
  • Monitor all of the firm’s Regulatory Element Continuing Education obligations for all of the firm’s registered personnel

Correspondence, Sales Literature and Advertising

  • Review and submit advertising to the FINRA Advertising Department
  • Review sales literature as needed
  • Complete a monthly email review

CRD Maintenance

  • Prepare and submit all Form U4 filings
  • Amend the Form BD as necessary
  • Conduct a monthly review to ensure that all CRD deficiencies are corrected
  • File all state registration applications as needed

Miscellaneous

  • Moderate the firm’s Annual Compliance Meeting
  • Conduct the annual FINRA Contact Questionnaire update
  • Review the firm’s annual Privacy Policy, AML, Order Routing, Business Continuity Plan, SIPC, disclosure
  • Conduct a monthly best execution review (if applicable)
  • Review the firm Fidelity Bond renewal
  • Update the firm MSRB G-40 contact information report
  • Provide training to the firm’s Compliance Department, branch and OSJ managers a nd executive management
  • Q&A as needed

3110(e) Background Checks

Thornton & Associates, LLC is a proud partner of Alliance Worldwide Investigative Group. Alliance Worldwide Investigative Group is an industry expert on FINRA Rule 3110(e): This background check rule was approved by the U.S. Securities and Exchange Commission and took effect on July 1, 2015.

Headquartered in Clifton Park, New York, Alliance Worldwide Investigative Group is a fully licensed, bonded and insured corporate investigative service firm. Alliance accommodates the needs of many industries focusing on assisting human resource, risk management, and legal professionals mitigate losses and make informed decisions.

Rule 3110(e) requires that each FINRA member “ascertain by investigation the good character, business reputation, qualifications and experience of an applicant before the member applies to register that applicant with FINRA and before making a representation to that effect on the application for registration.”

Rule 3110(e) requires the verification process be completed within 30 days of a broker’s Uniform Application for Securities Industry Registration or Transfer (Form U4) being filed. If possible, FINRA encourages firms to complete the new background check rule prior to the U4 filing. We are experts at conducting the mandatory search of “reasonable available public records” and if necessary, more in-depth searches depending on the applicant’s job function, responsibilities or position at the firm.

Alliance Worldwide Investigative Group takes the burden off FINRA member broker dealers and registered investment advisors by alleviating the time-consuming nature of sifting through records and navigating the new regulations. Our background investigation verifications are conducted in accordance with all applicable laws, rules and regulations, including federal and state requirements, making sure all necessary approvals, consents and authorizations are obtained.

Download white paper here.
Read related blog here.
Request information here.

Contact information:
Alliance Worldwide Investigative Group
23 Executive Park Drive
Clifton Park, New York 12065
Phone: (518) 514-AWIG (2944), (800) 579-2911; Fax: (518) 514-2947;
Email: sales@allianceinvestigative.com
www.AllianceInvestigative.com

3120 / 3130 Supervisory Testing

FINRA Rules 3120 and 3130 can be confusing and complicated to comply with. Thornton & Associates, LLC can provide your firm with the following services to assist you in complying with rules 3120 and 3130:

• Develop a quality 3120/3130 audit program
• Identify “Producing Managers”
• File the Small Firm Exemption if applicable
• Prepare 3120/3130 Written Supervisory Procedures
• Develop Heightened Supervisory Procedures for “Producing Managers”
• Coordinate the CEO and Chief Compliance Officer 3120/3130 meeting
• Prepare the CEO Certification

For more information about our 3120/3130 compliance services, please contact us at (877) 542-6759.

3110 Internal Audits

Thornton & Associates, LLC can develop an internal Rule 3110 audit program for you or we can come to your firm and conduct the audit in person. Our firm continually works with our clients during their FINRA, state and SEC audits and knows their audit processes, sampling, and current “hot topics.” During the Rule 3110 audit process, Thornton & Associates can help your firm identify regulatory exposures during your Rule 3110 internal review.

Both of our audit templates and on-site audit services include a review of the following:

  • Financial Statements and Net Capital
  • Written Supervisory Procedures
  • Books and Records review
  • Email and Correspondence
  • Website compliance
  • Transaction reporting
  • Continuing Education
  • Money Laundering
  • Suitability

Online Continuing Education

Thornton & Associates, LLC has partnered with QuestCE to create the Thornton & Associates Continuing Education Portal.  Through this portal we offer the complete QuestCE online continuing education and anti-money laundering training curriculum .

For over twenty-five years, Quest CE has been the premier provider of compliance training and tracking solutions to the financial services industry. QuestCE services more than 1,000 leading insurance carriers, broker-dealers, banks, and other financial institutions.

For more information about our Online Continuing Education Portal, please contact us at (877) 542-6759.

 

Written Supervisory Procedures

Every broker dealer is required to establish, maintain and enforce Written Supervisory Procedures that are designed to ensure compliance with all applicable regulatory rules and regulations. Thornton & Associates, LLC prides itself on its customized Written Supervisory Procedures. Our procedures are continuously reviewed by the SEC, FINRA and state regulatory agencies and are updated to reflect changes in rules and regulations.

Many firms sell boilerplate procedures or only provide them in an uneditable format. All of our procedures are customized and identify who is responsible for each procedure, how often each review is conducted, specifically how each review is performed and how each procedure is evidenced. Each of our clients is provided their complete Written Supervisory Procedures in Microsoft Word so that they can be edited at any time.

For more information about our Written Supervisory Procedures services, please contact us at (877) 542-6759.

Annual Compliance Meetings

Every Broker Dealer is required to conduct an Annual Compliance Meeting. If you would like a Thornton & Associates, LLC consultant to participate or moderate your Annual Compliance Meeting, please contact us at (877) 542-6759.

State Registrations

Expanding your firm’s operations may mean that your firm is required to register in other state jurisdictions. Each state has its own unique registration approval process. Thornton & Associates’ staff have completed hundreds of state registrations and understand the idiosyncrasies of each states registration process.

For assistance in state registrations, please contact us at (877) 542-6759.