How do I Write FINRA Policies & Procedures?

Writing policies and procedures for FINRA compliance is a challenging undertaking.

Writing a business standard practice for Financial Industry Regulatory Authority (FINRA) compliance is a painstaking process involving many steps. Before you can even begin to write policies and procedures, you must be thoroughly familiar with the "FINRA Rulebook" and, in turn, evaluate the impact it has on your current business operation. It is only through such understanding and careful analysis that you then can draft the requisite policies and procedures for FINRA compliance.

Instructions

Determine Policy and Procedure Requirements for FINRA Compliance

1. Ensure that all company policies, procedures and forms exactly describe current business practice. Re-document as necessary to ensure accuracy and completeness.

2. Review the "FINRA Rulebook" table of contents.

3. Sort current company policies and procedures according to the "FINRA Rulebook" section(s) to which they apply.

4. Compare current company policies and procedures to requirements specified in each "FINRA Rulebook" section. Note informational discrepancies and possible business areas necessitating change to allow compliance.

5. Create a list of the new and revised policies, procedures and forms required for FINRA compliance.

6. Make organizational changes as necessary for FINRA compliance.

Develop Requisite Source Information to Develop FINRA Policies and Procedures

1. Meet with functional managers and subject experts to identify policy and procedure content requirements.

2. Compare content requirements with those specified in the applicable "FINRA Rulebook" section(s). As necessary, convene subsequent meetings with functional managers and subject experts until all "FINRA Rulebook" section content requirements are satisfied.

3. Obtain sufficient source information from functional managers and subject experts to develop requisite policies and procedures.

Draft FINRA Policies and Procedures

1. Review the list of required FINRA policies and procedures that you created.

2. Review relevant source information provided by assigned functional managers and subject experts.

3. Draft an appropriate policy statement using a company documentation standard and policy writing template.

4. Develop the requisite forms and procedures to enforce or otherwise support each policy statement. This involves reviewing relevant source information and drafting forms and procedures per the company's documentation standard and writing templates.

   Develop forms and procedures for only a governing policy statement that was created.

5. Obtain responsible functional manager and subject expert approval for all FINRA-compliant policies, procedures and forms produced.

Tips & Warnings

• Writing FINRA-compliant policies and procedures can be expedited by first making a flowchart of business processes for which policies and procedures will be written.

• Development of FINRA policies and procedures in no way guarantees certification of FINRA compliance.

References

• "FINRA Rulebook;" FINRA Compliance Committee; 2010