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Strengthening Broker-Dealer Compliance & Supervisory Oversight

Broker-dealers operating in today’s regulatory environment face heightened scrutiny of their supervisory systems and internal controls. Annual supervisory control reporting — historically referred to as FINRA Rule 3012 and now governed under FINRA Rule 3120 — remains a critical regulatory requirement for demonstrating effective supervision and compliance oversight.

DuMont Consulting provides specialized support for Annual FINRA Rule 3012 Supervisory Control Reports, helping broker-dealers meet regulatory expectations while transforming annual reviews into strategic compliance tools rather than reactive obligations.

Understanding FINRA Rule 3012 & Rule 3120 Requirements

Under FINRA Rule 3120, broker-dealers must conduct an annual review of their supervisory control systems to assess whether policies and procedures are reasonably designed to achieve compliance with federal securities laws and FINRA rules.

These annual reviews must be documented in a supervisory control report provided to senior management and should address:

  • The effectiveness of supervisory procedures and controls

  • Testing and verification of compliance systems

  • Identification of material weaknesses or exceptions

  • Remedial actions taken or planned

For firms with higher revenue thresholds or complex business models, additional reporting requirements — including customer complaint analysis and supervisory trends — may apply.

Failure to properly document or conduct these reviews can result in regulatory findings, enforcement actions, or increased examination scrutiny.

How DuMont Consulting Supports Annual Supervisory Control Reports

DuMont Consulting delivers comprehensive, exam-ready FINRA Rule 3012 and Rule 3120 compliance support, tailored to each firm’s size, risk profile, and operational complexity.

Comprehensive Supervisory System Reviews

Our consultants conduct in-depth evaluations of supervisory controls across key compliance areas, including:

  • Sales practice supervision

  • Communications and correspondence monitoring

  • Customer complaint handling

  • Conflicts of interest oversight

  • Escalation and remediation procedures

This approach ensures supervisory systems function effectively in practice — not just on paper.

Clear, Defensible Documentation for Senior Management

DuMont prepares supervisory control reports that clearly articulate:

  • Areas of supervisory strength

  • Identified gaps or control weaknesses

  • Practical, risk-based recommendations

Our reports are structured to withstand regulatory examination while providing senior leadership with actionable compliance insights.

Integrated Outsourced CCO Services

For firms leveraging outsourced CCO services for investment firms, annual supervisory control reporting becomes part of a continuous compliance lifecycle. DuMont integrates Rule 3012 reviews with:

  • Written Supervisory Procedures (WSPs)

  • Regulatory filings and disclosures

  • Prior exam findings and remediation tracking

  • Ongoing compliance monitoring

This proactive model reduces regulatory risk and strengthens long-term compliance posture.

Turning Annual Reviews Into Strategic Compliance Assets

Rather than treating annual supervisory control reports as a regulatory checkbox, broker-dealers can use this process to:

  • Identify emerging compliance risks early

  • Improve supervisory accountability

  • Strengthen internal controls and governance

  • Enhance readiness for FINRA examinations

With experienced guidance, annual FINRA Rule 3012 reviews become an opportunity to reinforce a strong compliance culture and demonstrate regulatory diligence.

Partner With DuMont Consulting

DuMont Consulting brings deep regulatory expertise to Annual FINRA Rule 3012 Supervisory Control Reports, helping broker-dealers meet FINRA expectations with confidence and clarity. Whether as a standalone engagement or as part of outsourced CCO services, our approach ensures supervisory reviews are thorough, defensible, and aligned with regulatory priorities.

Contact DuMont Consulting to strengthen your supervisory controls and ensure your annual FINRA compliance reviews are examination-ready.

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