Risk Assessments/Testing

FINRA Supervisory Controls Review & CEO Certification (FINRA Rules 3120/3130)

• J&J will conduct an analysis of the existing risk assessment or generate one for comparison to the Firm’s existing procedures and controls.
• Highlight those areas that will be the subject of testing for the annual 3120 review
• Conduct tests of the highlighted areas and maintain thorough documentation of all tests with results and remediation plans.
• Update procedures as needed and assist with recommended remediations

FINRA Branch Reviews (FINRA 3110(c))

• Annual branch review which will cover all aspects of 3110( c)(2) and (3) and 3110(d)
• Collect necessary document to evidence proper audit trail and conduct interviews as needed
• J&J will draft the inspection report and assist with any remediation steps required

Market Access Rule (SEC Rule 15c3-5)

• Assess the connections to exchanges/ATSs for inclusion into existing risk management and surveillance systems
• Evaluate risk limits process for setting and adjusting limits and aggregating orders within accounts
• Evaluate and test systemic controls in place including soft and hard blocks
• Evaluate access protocols
• Draft report identifying any gaps or areas for improvement as well as potential remediation steps