and enforce written supervisory procedures (WSPs) reasonably designed to supervise the activities of its The supervisory review to be conducted by the CCO (or qualified delegate); The timing of the supervisory review (note that "periodic" and "when necessary" are too broad); and Description of the record corroborating the Written Supervisory Procedures Manual SAMCO Capital Markets, Inc. March 27, 2013. SAMCO Capital Markets, Inc. - i - March 27, 2013 TABLE OF CONTENTS The SEC has adopted an anti-fraud rule titled "Compliance Procedures and Practices" (Rule 206(4)-7) under the Advisers Act requiring written compliance programs for all SEC registered advisers. The Compliance Procedures and Practices rule makes it unlawful for an SEC adviser to provide investment advice to clients unless the adviser: these Written Supervisory Policies and Procedures ("WSPs") in a current manner. ompliance is responsible for disseminating information required for associated personnel to conduct their business in a manner that encompasses all laws, rule, regulations and interpretations. The first step to determine what areas should be covered in an investment adviser's written supervisory and compliance policies and procedures is to perform a risk analysis of the investment adviser. This means that the registered investment adviser should identify conflicts of interest, business practices, arrangements, and other compliance 68 - ARCHIVING COMPLIANCE SUPERVISORY AND PROCEDURES MANUALS 69 - ASSETS: Independent Verification of Proprietary or Customer Assets 70 - ASSOCIATED PERSONS RECORDS 71 - BANK SECRECY ACT (BSA) FORM SAR-SF: Requirements Beyond Money Laundering Activities 72 - BEST EXECUTION: FINRA Guidance Written Supervisory Procedures Checklist for Funding Portals Overview - This Written Supervisory Procedures Checklist ("WSP Checklist") outlines selected key topics as a reference tool to assist funding portal members ("FP members") in fulfilling their compliance obligations. The Written Supervisory Procedures Manual was written to comply with FINRA Rule 3110 and is intended as a guide for the firm to achieve and maintain compliance with FINRA and SEC rules and regulations and is used to supervise the activities Designated Principal, its Registered Individuals and additional Associated Persons. The establishment of written supervisory procedures should be viewed as a dynamic document subject to change. The procedures should be inclusive of current material changes in SEC, FINRA and/or applicable state rules and regulations based on periodic regulatory notifications, releases, regulatory alerts, rule proposals, and/or relevant industry Written Supervisory Procedures Manual SAMCO Capital Markets, Inc. September 13, 2013. SAMCO Capital Markets, Inc. - i - September 13, 2013 TABLE OF CONTENTS Written Supervisory Procedures Manual Table of Contents INTRODUCTION ABBREVIATIONS USED IN THIS MANUAL 1.0 DESIGNATION OF SUPERVISORS 2.0 GENERAL EMPLOYEE POLICIES 2.1 Standards of Conduct 2.2 Outside Business Activities 2.3 Private Securities Transactions 2.4 Employee and Employee Related Accounts G-44 to establish and maintain written compliance policies and written supervisory procedures (WSPs).1 This compliance resource does not create new legal or regulatory requirements, or new interpretations of existing requirements, and municipal advisors, enforcement agencies and others should not view this informatio