What is the difference between the Rule 3012 report and the Rule 3013 report?
A. The NASD Rule 3013 report identifies the processes a firm follows to establish, maintain, review, test and modify its written compliance policies and written supervisory procedures. FINRA typically reviews the 3013 report so that the staff can understand the processes that a firm follows to establish and update written policies and procedures. The Rule 3013 report is the work plan (a detailed outline of steps) that a firm uses to adopt and keep current supervisory policies and procedures under Rule 3010 and to adopt SCPs required under Rule 3012. FINRA recommends that firms review the results of their 3012 report in considering whether their Rule 3013 processes are sufficient. For example, if a firm’s Rule 3012 report consistently notes a firm’s failure to adopt WSPs around new regulatory requirements, then a firm should consider whether its Rule 3013 processes adequately take into account new regulatory requirements. In contrast, the Rule 3012 report is not a work plan (except to t
