Series 99: 3.3.1.2 Third-Party Vendors: Compliance Responsibilities

3.3.1.2  Third-Party Vendors: Compliance Responsibilities

Broker-dealers commonly use third-party vendors to perform many of their functions, such as IT services, order management, and legal and compliance services. Many of these vendors are foreign or domestic unregulated entities. Any third-party service providers conducting activities that require registration and qualification under FINRA rules are considered associated persons of the firm and must have all necessary registrations and qualifications.

Accordingly, a firm’s supervisory system must include procedures to ensure regulatory compliance regarding its outsourcing practices. The firm’s written supervisory procedures (WSPs) must require a due diligence analysis to determine the capabilit