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