You know what’s not my idea of a good time?
Trying to decode FINRA rules.
It’s easy to get lost in the fine print. Rule 3110 comes with a schedule. This is what’s due, and when. For what the rule requires and what examiners look for, see our FINRA Rule 3110 guide.
What’s due when
| Task | How often | Rule |
|---|---|---|
| Review your businesses | At least once each calendar year | 3110(c)(1) |
| Meet with each registered person | At least once a year | 3110(a)(7) |
| Inspect OSJs and supervising branches | At least once each calendar year | 3110(c)(1)(A) |
| Inspect other branch offices | At least every three years | 3110(c)(1)(B) |
| Inspect non-branch locations | On a regular schedule, presumed to be at least every three years | 3110(c)(1)(C), 3110.13 |
| Report new investigations (investment banking) | Within 10 business days after the quarter ends | 3110(d)(3)(A) |
| Report a confirmed violation | Within 5 business days of completion | 3110(d)(3)(B) |
| Investigate flagged trades | Promptly | 3110(d)(2) |
| Update WSPs after rule changes | Promptly | 3110(b)(7) |
| Keep supervisor designation records | At least three years | 3110(b)(6)(B) |
| Join the remote inspections pilot | By December 27, 2026 | 3110.18 |
Every year
At least once each calendar year, review the businesses your firm is in. Each registered representative and principal also needs a compliance meeting or interview at least once a year. Every office of supervisory jurisdiction (OSJ), and every branch office that supervises non-branch locations, must be inspected at least annually.
At least every three years
Branch offices that don’t supervise any non-branch locations must be inspected at least every three years. Non-branch locations are inspected on a regular schedule, presumed to be at least every three years unless your firm documents why a longer cycle is appropriate.
Those are minimums. Your risk profile can call for more.
And don’t forget—you’ve got to document all of this. FINRA doesn’t care if you’ve got an entire firm made up of people with eidetic memory. Document it.
Every quarter
If your firm provides investment banking services, report the internal investigations you opened during the quarter. The report is due within 10 business days after the quarter ends and must be signed by a senior officer.
Within five business days
Ongoing
FINRA wants you watching for sketchy trades.
Your firm needs a process in place to catch trades that might involve things like insider trading or market manipulation—and not just in client accounts.
What kinds of accounts need to be monitored?
- Your firm’s own accounts
- Accounts where your employees have a stake or make trading decisions
- Accounts tied to employees’ family members
- Any other accounts you’re required to track under FINRA Rule 3210 (Yes, another rule…)
If something looks off? Investigate it. Fast. If a trade raises a red flag, you’re expected to look into it right away—don’t let it sit.
Review business communications
If it’s business-related, it gets reviewed, wherever it happens: email, texts, WhatsApp, iMessage, LinkedIn DMs. Your tools should cover the apps your team actually uses (👋 you know, like Comma). For what the review requirement covers, see our Rule 3110 guide.
Documentation or It Didn’t Happen
If you can’t show it, you didn’t do it. FINRA Rule 3110 demands detailed records of reviews and supervisory actions. That means archiving isn’t just nice to have—it’s mission-critical.
So if your system isn’t built to document, track, and store that information… you’re flying blind.
When something changes
When securities laws or FINRA rules change, amend your WSPs promptly. When you designate a supervisor, keep a record of it for at least three years.
Written Supervisory Procedures (WSPs)
These are the “how-to” guides your firm uses to keep people on track. Think of them as your compliance GPS—if they’re out of date or unclear, someone’s getting lost.
Who’s Watching Who?
You’ve got to clearly designate supervisors—and they’ve got to be qualified. No one gets to supervise just because they’ve been around a while.
Rule 3110 flat-out bans people from supervising themselves. (That means no self-review, and no weird org charts where someone reports to the person they’re supervising.) Sounds obvious—but in smaller firms, it can get complicated.
What’s changing: remote inspections
Remote inspections in place of on-site visits are allowed under a pilot program (Rule 3110.18). The pilot began on July 1, 2024, and is scheduled to end on June 30, 2027.
On June 11, 2026, FINRA’s Board of Governors approved making the program permanent and sent the proposal to the SEC for final approval. Until the SEC acts, the pilot’s terms still apply.
Firms already in the pilot stay in for each new pilot year unless they withdraw. Firms that want to join for the final period, January 1 to June 30, 2027, must opt in by December 27, 2026. If you inspect remotely, document why each location qualifies and how you reviewed it.
Putting It All Together
Rule 3110 isn’t trying to make your life harder—it’s trying to keep your firm out of trouble before it happens. That means building supervision systems that actually work in the real world—where reps use phones, not faxes, and messages that get lost in the abyss.
If your compliance process feels like the tail wagging the dog—overcomplicated, reactive, or duct-taped together—it’s time to rethink the tools you’re using.
Start by asking:
- Do you know when every office’s next inspection is due?
- Could you file a violation report within five business days of closing an investigation?
- Have your WSPs caught up with this year’s rule changes?
You don’t need to boil the ocean—just get the fundamentals right. We can help with that. And we’ll even keep the legalese to a minimum.
TL;DR
If you remember one thing about FINRA Rule 3110, make it this:
“Supervise smartly, document everything, and don’t let anything fall through the cracks.”
We help make that happen—without slowing your team down.
Last updated: September 2026. Reviewed periodically for accuracy as FINRA guidance evolves.
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