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Should You Purchase a Written Supervisory Procedures Template?

 
Tuesday, May 18, 2021

Purchasing a template written supervisory procedures compliance manual is commonplace happening in the industry. After all, it seems like a great solution to the problem of carving out time and creating a lengthy and complex guide from scratch.  

These templates can be beneficial for a few reasons:  

They’re timesavers.  

When you build a manual on your own, you’re investing hours upon hours of your team’s time to research and create a guide. Those hours translate to dollars, as you pay your compliance people to work on this project and as it delays their efforts on other compliance processes, from filings/registrations to advertising reviews 

You’ll have specific details you need to customize within your compliance manual. However, having a starting point can save a lot of time that you might spend on just getting the basic criteria outlined.  

They build on others’ expertise.  

When you work with a compliance consulting firm that can provide you a template for your manual, you benefit from the time they’ve spent researching and the insight they’ve gained from working with other firms. If your compliance consultant serves a number of other firms, they’ve likely encountered situations that haven’t been on your radar and can provide useful information that might take your team an extended length of time to uncover.  

They have the potential to reduce costs.  

It sounds like a win-win situation, doesn’t it? While purchasing a manual template can make for a great starting point, you have to ensure it is just that—a starting point, not your final product.  

What Issues Might Arise From Purchasing a Written Supervisory Procedures Manual Template?  

Once you buy your template, you can’t allow it to sit on a shelf waiting for your next examinationA written compliance manual template is not a document that is purchased to ensure compliance with the rules. 

Instead, when the purchase is complete…that’s when your work begins. The purpose of a template compliance manual is to provide a starting place for written procedures designed to ensure a firm complies with the rules and regulations under which it operates.  

Once a compliance manual has been purchased, it should also be read, reviewed, and amended according to the firm’s practices. Your team needs to find the places in the template that require specific updates and references to your internal policies.  

And once the document has been reviewed and amended, it should be reviewed regularly to ensure new regulations are addressed and ensure there are no aspects of the business that have changed and are not adequately addressed.  

How Do I Ensure My Manual is Ready for an Examiner’s Review?  

Your compliance manual’s sole purpose is to provide an outline of the firm’s supervisory system and a tool for compliance personnel to ensure they can properly supervise the firm’s employees.  

You need to ensure your manual is:  

  • Up-to-date and reviewed regularly.  
  • Notated when changes are made and issues addressed. 
  • Reviewed by experts within your firm, as well as by external compliance consultants. 
  • Accessible to your team members. Distribute the manual to all personnel, so you can ensure everyone is familiar with the policies of the firm and the regulations under which it operates. 

It only takes one employee’s lapse in procedure to have a serious negative impact on the firm (see this article on a firm’s refund of almost $300,000 to clients and $75,000 fine because of a lack of an appropriate supervisory policy.  

By ensuring you’ve created and disseminated an appropriate compliance procedure manual, one that’s customized to your firm, you protect your firm from this additional stress and financial strain. Contact our compliance consultants to discuss the resources we provide, from creating manuals for your team to reviewing an existing manual.