Supervision queue
What the agents found, what they prepared, and every draft waiting for release. The disposition is yours.
The desks swept 7 accounts and 5 captured messages on email. 12 findings wait on a principal, 2 blocking; each arrives with the facts read, the citation and what the agent prepared.
- Business conducted on an uncaptured channel: Record completeness
- Performance or testimonial content in advisory-capacity material: Renner: email sent 2 days ago
An agent detects, cites and prepares. It never clears its own finding; you clear, return or block, and the disposition is recorded against the rules as they stood.
12
Open findings
2
Blocking
0
Drafts awaiting release
7 + 5
Accounts and captured messages swept, email
1 captured message not swept
What the agents found, without being asked
What is autonomous here, and what is not
Business conducted on an uncaptured channel
Record completeness · Record completeness · SEC Rule 17a-4; Exchange Act Section 17(a)
calendar, voice, sms, chat, social in use with nothing capturing them. Record completeness is 0.36.
Suggested: Connect a capture source for each channel, or prohibit the channel and attest to it.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
record-completeness:off-channel-gap:adv-aPerformance or testimonial content in advisory-capacity material
Renner: email sent 2 days ago · Marketing review · SEC Rule 206(4)-1, Advisers Act marketing rule
Client-facing text contains performance projection or testimonial content.
Suggested: Remove it. The firm blocks projections in client-facing drafts entirely while the FINRA projections proposal is unadopted.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
marketing-review:sec-marketing-206-4-1:msg-001Concentration rising toward the household's ceiling
Abernathy · Sales practice · FINRA Rule 2111(a), quantitative suitability, read over time rather than at a point
Inherited utility holding has risen 6.6 points in 90 days to 38% against the household's 30% ceiling (day -90: 31.4%, day -60: 33.9%, day -30: 36.2%, day 0: 38%).
Suggested: Raise it with the client before the ceiling is crossed: a staged plan now is cheaper than a forced trim later. Record the conversation on the account.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
sales-practice:finra-2111-drift:hh-abernathyConcentration rising toward the household's ceiling
Thornbury · Sales practice · FINRA Rule 2111(a), quantitative suitability, read over time rather than at a point
Operating business stake (illiquid) has risen 9.1 points in 90 days to 77.1% against the household's 80% ceiling (day -90: 68%, day -60: 71.5%, day -30: 74.2%, day 0: 77.1%).
Suggested: Raise it with the client before the ceiling is crossed: a staged plan now is cheaper than a forced trim later. Record the conversation on the account.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
sales-practice:finra-2111-drift:hh-thornburyHoldings drifted outside the stated profile
Abernathy · Sales practice · FINRA Rule 2111
Inherited utility holding is 38 percent of investable assets against a ceiling of 25.
Suggested: Document the rationale for holding, or propose a bounded reduction from the approved shelf.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
sales-practice:finra-2111-suitability:hh-abernathyHoldings drifted outside the stated profile
Renner · Sales practice · FINRA Rule 2111
Founder single-name position is 71 percent of investable assets against a ceiling of 25.
Suggested: Document the rationale for holding, or propose a bounded reduction from the approved shelf.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
sales-practice:finra-2111-suitability:hh-rennerHoldings drifted outside the stated profile
Thornbury · Sales practice · FINRA Rule 2111
Operating business stake (illiquid) is 77.1 percent of investable assets against a ceiling of 25.
Suggested: Document the rationale for holding, or propose a bounded reduction from the approved shelf.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
sales-practice:finra-2111-suitability:hh-thornburyCorrespondence not reviewed under written supervisory procedures
Renner: email sent 2 days ago · Communications surveillance · FINRA Rule 3110(b), 3110.06 to .09
Correspondence carrying a recommendation has not been through supervisory review.
Suggested: Queue for review under the written supervisory procedures. Pre-approval is not required at this distribution.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
communications-surveillance:finra-3110-correspondence:msg-001No retained copy behind a captured channel
Record completeness · Record completeness · SEC Rule 17a-4(b)(4), 17a-4(f)
meeting, crm captured but held by no system of record. Evidence exists and retention does not.
Suggested: Point the channel at the archive, which is the 17a-4 copy, by WORM or the audit-trail alternative.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
record-completeness:sec-17a4-completeness:adv-aPossible diminished capacity or financial exploitation
Okafor-Lind · Vulnerable client protection · FINRA Rules 2165 and 4512(a)(1)(F)
Specified adult aged 79 with an exploitation indicator present.
Suggested: Escalate for a hold decision under Rule 2165 and confirm a trusted contact is on file.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
client-protection:senior-investor-2165:hh-okafor-lindPossible diminished capacity or financial exploitation
Abernathy · Vulnerable client protection · FINRA Rules 2165 and 4512(a)(1)(F)
Nothing fired, but this rests on an inferred fact at 70 percent confidence against a floor of 80.
Suggested: Confirm or correct the inferred fact, then the verdict stands on its own.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
client-protection:senior-investor-2165:hh-abernathyPossible diminished capacity or financial exploitation
Alcott · Vulnerable client protection · FINRA Rules 2165 and 4512(a)(1)(F)
Nothing fired, but this rests on an inferred fact at 70 percent confidence against a floor of 80.
Suggested: Confirm or correct the inferred fact, then the verdict stands on its own.
Recorded for this session. In production this is an immutable supervisory record (PRD FR-14).
client-protection:senior-investor-2165:hh-alcottThe rules behind these findings are editable on Rules and agents, and every change is in the change log.