2.1.6.1. Supervisory Control Procedures
The written supervisory controls must include policy and procedures designed to:
• Review and supervise customer account activity conducted by the firm’s producing managers. This responsibility must be performed by a person who is either senior to or independent of the producing manager and who is situated in a separate office. If the member firm is so small that it has no qualified senior manager to perform these duties, supervision and reviews may be conducted by some other knowledgeable principal. The member firm must first notify FINRA within 30 days of implementing this exception (and annually thereafter), and it must document in its supervisory control procedures the factors that make strict co