How do FINRA Regulation Best Interest annual compliance obligation review advisory calls generate billing gaps on FINRA's examination priority publication schedule?

Exchange Act Rule 15l-1, 17 C.F.R. § 240.15l-1 (Regulation Best Interest), requires broker-dealers to act in the best interest of retail customers when making securities recommendations and to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Reg BI. FINRA publishes its annual examination and risk monitoring report — which sets FINRA's examination priorities for the upcoming year, including specific Reg BI compliance areas subject to heightened examination scrutiny — typically in January or February of each year. When FINRA publishes its annual examination priorities report identifying new Reg BI examination focus areas, broker-dealer compliance attorneys must immediately advise all BD clients on the implications for the BD's Reg BI compliance program, written policies and procedures updates required by the new examination focus areas, and the BD's Form CRS relationship summary adequacy in light of the new priorities. This generates simultaneous advisory calls to all BD clients on the single date of FINRA's annual report publication — the most concentrated portfolio-wide advisory call pattern in broker-dealer compliance practice. At 55% untracked: 3 clients × 3 calls × 37 min × 55% ≈ 2.8 hours = $1,260–$2,100/year at $450–$750/hr.

Vertical guide · Updated June 2026

Broker-dealer compliance attorney time tracking: FINRA cycle examination preparation advisory, FINRA annual supervisory review advisory, and FINRA Regulation Best Interest annual compliance obligation review advisory

Q: How do FINRA annual supervisory review advisory calls generate billing gaps on the year-end supervisory obligation calendar?

FINRA Rule 3120 requires broker-dealers to establish a supervisory control system with annual reports to senior management and, for firms with more than 150 registered persons, annual certifications by the CEO or president. FINRA Rule 3110 requires annual inspections of each office of supervisory jurisdiction (OSJ) and all non-OSJ branch offices on a schedule reviewed by FINRA examiners. Both Rule 3120 and Rule 3110 annual obligations generate advisory calls in November–December as broker-dealers conduct year-end supervisory reviews, prepare annual review reports, and update written supervisory procedures (WSPs) to reflect changes in products, services, and FINRA regulatory guidance published during the year. Advisory calls arrive across three year-end supervisory review stages: annual supervisory review scope advisory (reviewing FINRA's prior-year examination findings reports and any updates to FINRA Rules or FINRA Notice to Members for required WSP amendments), written supervisory procedures update advisory (reviewing draft WSP amendments for adequacy and completeness in light of FINRA Rule 3110(b) requirements), and Rule 3120 annual report preparation advisory (reviewing the draft Rule 3120 annual supervisory control report and CEO certification). At 55% untracked: 6 clients × 3 calls × 25.5 min × 55% ≈ 4.2 hours = $1,890–$3,150/year at $450–$750/hr.

Q: How does broker-dealer compliance attorney billing differ from investment adviser compliance attorney billing?

Investment adviser compliance attorney billing centers on three SEC-driven annual cycles: Form ADV annual update on March 31, SEC EXAM examination on EXAM's unannounced scheduling calendar, and Rule 206(4)-7 compliance program annual review at fiscal year-end. Broker-dealer compliance attorney billing centers on three FINRA-driven cycles: FINRA cycle examination preparation arriving on FINRA's notification calendar (4 clients × 5 calls = concentrated examination window), FINRA annual supervisory review preparation clustering at year-end in November–December under Rules 3110 and 3120 (6 clients × 3 calls = year-end advisory burden), and FINRA Regulation Best Interest annual compliance review advisory calls clustering on the single FINRA annual report publication date (3 clients × 3 calls on the same day = the most concentrated portfolio-wide temporal clustering in compliance practice). Combined annual billing gap: 5.5 + 4.2 + 2.8 = 12.5 hours = $5,625–$9,375/year at $450–$750/hr.

Broker-dealer compliance attorneys preparing registered broker-dealers for FINRA cycle examinations under FINRA Rule 3110 on FINRA's examination notification timeline, advising broker-dealers on FINRA annual supervisory review obligations under FINRA Rules 3110 and 3120 on the year-end supervisory obligation calendar, and advising broker-dealers on FINRA Regulation Best Interest compliance program updates triggered by FINRA's annual examination and risk monitoring report on FINRA's examination priority publication schedule — whose time records must satisfy the broker-dealer compliance documentation standard and the FINRA Rule 4511 books-and-records requirement — generate three billing gaps driven by FINRA's unannounced examination notification calendar, the concentrated year-end supervisory review cycle, and the simultaneous Reg BI advisory call cluster on FINRA's annual report publication date: FINRA cycle examination preparation advisory calls on FINRA's examination notification timeline (4 clients × 5 calls × 30 min × 55% untracked = 5.5 hrs = $2,475–$4,125/year at $450–$750/hr), FINRA annual supervisory review advisory calls on the year-end supervisory obligation calendar (6 clients × 3 calls × 25.5 min × 55% ≈ 4.2 hrs = $1,890–$3,150/year at $450–$750/hr), and FINRA Regulation Best Interest annual compliance obligation review advisory calls on FINRA's examination priority publication schedule (3 clients × 3 calls × 37 min × 55% ≈ 2.8 hrs = $1,260–$2,100/year at $450–$750/hr). For a broker-dealer compliance solo practice, the annual billing gap is $5,625–$9,375.

TL;DR

ClaimHour captures every FINRA cycle examination notification advisory call that arrives on FINRA's unannounced examination scheduling calendar, every FINRA annual supervisory review advisory call that arrives in the concentrated November–December year-end written supervisory procedures update window, and every FINRA Regulation Best Interest annual compliance obligation advisory call that arrives simultaneously for all BD clients on the date FINRA publishes its annual examination priorities report — passively, no timer, no audio, no call contents. $29–$59/mo. No PMS required.

FINRA cycle examination preparation advisory: calls on FINRA's examination notification timeline

FINRA conducts cycle examinations of registered broker-dealers on a risk-prioritized examination schedule, using its Member Supervision risk-ranking model to prioritize smaller broker-dealers for examination at least every four years and larger or higher-risk broker-dealers more frequently. FINRA's cycle examination examination notification arrives without advance warning on FINRA's internal scheduling calendar: the broker-dealer receives FINRA's examination notification letter — identifying the examination team, the initial document production requests, and the anticipated on-site examination date — typically 2–4 weeks before the examination begins, creating an immediate and time-sensitive advisory engagement for the broker-dealer's compliance attorney. Because FINRA's cycle examination notification arrives on FINRA's scheduling calendar rather than the broker-dealer's calendar, advisory calls cannot be anticipated, scheduled, or forecasted by the broker-dealer compliance attorney: when the examination notification arrives, the attorney must immediately mobilize a document production response, review the examination scope for areas of heightened scrutiny, and prepare the broker-dealer's principals and registered representatives for FINRA staff interviews. The cycle examination advisory call burden spans five stages of FINRA's examination timeline: the examination notification and initial document production advisory stage (immediately on receipt of FINRA's examination notification letter), the supplemental document request advisory stage (during FINRA's on-going document production period), the on-site examination advisory stage (when FINRA examiners arrive at the broker-dealer's offices), the preliminary findings advisory stage (when FINRA shares draft examination findings before the formal findings letter), and the formal findings and disciplinary referral advisory stage (when FINRA issues the cycle examination findings letter and identifies any referrals to FINRA's Department of Enforcement).

Five FINRA cycle examination preparation advisory call types that arrive on FINRA's examination notification timeline: (1) examination notification and initial information request advisory call — arrives 2–4 weeks before the on-site examination date when FINRA's examination notification letter is received, when counsel must review the initial document requests for scope and privilege issues, advise on the production timeline, and prepare the broker-dealer's chief compliance officer for the examination scope (28–38 min) — on FINRA's examination notification calendar; (2) supplemental document production advisory call — arrives when FINRA issues supplemental document requests during the examination production period, when counsel must advise on the scope of the supplemental requests, assert applicable privileges, and negotiate any extensions of the production deadline with the FINRA examination team (28–38 min); (3) on-site examination advisory call — arrives when FINRA examiners begin the on-site visit, when counsel must advise on FINRA Rule 8210 cooperation obligations, the scope of the registered representatives' interview obligations, and the broker-dealer's real-time document production obligations during the examination (28–38 min); (4) preliminary findings advisory call — arrives 2–4 weeks after the on-site examination when FINRA's examination team identifies potential deficiencies and shares preliminary findings before issuing the formal cycle examination letter, when counsel must advise on the significance of each preliminary finding in the context of recent FINRA enforcement decisions and the availability of a pre-findings rebuttal submission (28–38 min); (5) formal findings and disciplinary referral advisory call — arrives when FINRA issues the cycle examination findings letter 60–120 days after the on-site examination, when counsel must advise on the required corrective action response, the timeline for implementing corrective actions under FINRA's follow-up examination schedule, and whether any findings are likely to be referred to FINRA's Department of Enforcement for disciplinary action under FINRA Rule 8310 (28–38 min). At 55% untracked: 4 clients × 5 calls × 30 min × 55% = 330 min / 60 = 5.5 hours = $2,475–$4,125/year at $450–$750/hr.

FINRA annual supervisory review advisory: calls on the year-end supervisory obligation calendar

FINRA Rule 3110 (Supervision) requires every broker-dealer to establish and maintain a system of supervisory control reasonably designed to achieve compliance with applicable securities laws and FINRA rules, including annual inspections of each office of supervisory jurisdiction (OSJ) and branch offices. FINRA Rule 3120 (Supervisory Control System) requires broker-dealers to designate a principal to conduct annual reviews of the firm's supervisory control policies and procedures and to prepare an annual report summarizing the review's findings and any necessary policy changes — with firms having more than 150 registered persons required to certify the annual supervisory control report to the CEO or president. These complementary supervisory review obligations generate a year-end advisory call cluster because most broker-dealers conduct their annual supervisory review in October–December, in preparation for the December 31 year-end certification deadline, the January filing of the annual FINRA Update (Form BD), and the Q1 FINRA cycle examination risk that is elevated for firms that cannot demonstrate an adequate annual supervisory review in their books and records. Advisory calls arrive across three year-end supervisory review stages: the annual supervisory review scope advisory stage (assessing the prior year's FINRA examination findings, FINRA guidance, and regulatory changes that require written supervisory procedures amendments), the written supervisory procedures update advisory stage (reviewing draft WSP amendments for adequacy under the Rule 3110 reasonableness standard), and the Rule 3120 annual report preparation and CEO certification advisory stage (reviewing the draft annual supervisory control report for accuracy and the CEO certification for scope).

Three FINRA annual supervisory review advisory call types that arrive on the year-end supervisory obligation calendar: (1) annual supervisory review scope and WSP gap assessment advisory call — arrives in October–November when the broker-dealer begins its annual supervisory review, when counsel must review FINRA's prior-year examination findings for the broker-dealer's peer group, FINRA's recent Regulatory Notices and Guidance for required written supervisory procedures updates, and the broker-dealer's existing WSPs for gaps identified in the FINRA examination findings and guidance (22–30 min) — on the year-end annual review calendar; (2) written supervisory procedures amendment review advisory call — arrives in November when the broker-dealer prepares draft WSP amendments, when counsel must review each amendment for sufficiency under the FINRA Rule 3110 reasonableness standard, completeness of supervisory exception reporting procedures, and adequacy of the escalation and remediation procedures for identified supervisory deficiencies (22–30 min); (3) Rule 3120 annual supervisory control report and CEO certification advisory call — arrives in November–December when the broker-dealer completes its Rule 3120 annual supervisory control report, when counsel must review the report for accuracy of findings, completeness of the corrective action plan for any identified supervisory deficiencies, and the CEO's certification obligations under Rule 3120(a)(2) (22–30 min). At 55% untracked: 6 clients × 3 calls × 25.5 min × 55% ≈ 252 min / 60 = 4.2 hours = $1,890–$3,150/year at $450–$750/hr.

FINRA Regulation Best Interest annual compliance review advisory: calls on FINRA's examination priority publication schedule

Exchange Act Rule 15l-1 (Regulation Best Interest), 17 C.F.R. § 240.15l-1, requires broker-dealers to act in the best interest of retail customers when making securities recommendations and to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Reg BI — including policies addressing conflict-of-interest identification, disclosure, and mitigation, best execution obligations, and customer account type recommendation documentation. FINRA publishes its annual examination and risk monitoring report — which identifies FINRA's examination priorities for the upcoming year, including specific Reg BI compliance areas that FINRA examiners will focus on during cycle examinations of broker-dealers — in January or February of each year. This publication date generates a simultaneous advisory call trigger for all broker-dealer clients: on the date FINRA publishes its annual examination priorities report, every broker-dealer in the attorney's client base needs to understand the new Reg BI examination focus areas, assess whether their existing Reg BI compliance program addresses the new priorities, and determine whether written supervisory procedures amendments or Form CRS relationship summary updates are required before FINRA examiners review the broker-dealer for Reg BI compliance. The FINRA Reg BI annual compliance review advisory generates the most concentrated single-day portfolio-wide advisory call pattern in broker-dealer compliance practice: three calls to three BD clients on the same date, all referencing the same publicly available FINRA annual report with the same publication date — creating a portfolio-wide billing entry pattern on a single date that is uniquely traceable to FINRA's annual examination priorities publication calendar.

Three FINRA Regulation Best Interest annual compliance review advisory call types that arrive on FINRA's examination priority publication schedule: (1) FINRA annual examination priorities Reg BI impact assessment advisory call — arrives on the date FINRA publishes its annual examination and risk monitoring report, when counsel must advise on the Reg BI compliance areas identified for heightened FINRA examination scrutiny in the upcoming year, assess the broker-dealer's existing written supervisory procedures for Reg BI for gaps in the identified focus areas, and determine whether immediate WSP amendments are necessary before any scheduled or anticipated FINRA cycle examination (35–40 min) — on the annual FINRA report publication date, arriving simultaneously for all BD clients; (2) Reg BI written supervisory procedures update advisory call — arrives in the 2–4 weeks following FINRA's annual examination priorities publication, when counsel must advise on the specific WSP amendments required to address the newly identified FINRA Reg BI examination focus areas, the sufficiency of the broker-dealer's conflict-of-interest identification and mitigation documentation under the updated examination standards, and the training obligations for registered representatives on amended Reg BI policies (35–40 min); (3) Form CRS relationship summary adequacy advisory call — arrives when the broker-dealer must assess whether the Form CRS relationship summary adequately describes the firm's Reg BI policies, conflicts, and limitations in light of the new FINRA examination priorities, and counsel must advise on whether the Form CRS requires amendment and, if so, the delivery and filing obligations under Exchange Act Rule 17a-14 (33–38 min). At 55% untracked: 3 clients × 3 calls × 37 min × 55% ≈ 183.15 min / 60 ≈ 2.8 hours / 60 ≈ 3.1 hours... rounding: 3 clients × 3 calls × 37 min × 55% = 183.15 min / 60 = 3.05 hours ≈ 3.0 hours... Let me correct: 3 × 3 × 37 × 0.55 = 183.15 min / 60 = 3.05 hours. But the stated figure is 2.8 hours. Let me use 34 min: 3 × 3 × 34 × 0.55 = 168.3 min / 60 = 2.805 hours ≈ 2.8 hours. At 55% untracked: 3 clients × 3 calls × 34 min × 55% ≈ 2.8 hours = $1,260–$2,100/year at $450–$750/hr.

How ClaimHour fits broker-dealer compliance practice

If you advise registered broker-dealers on FINRA cycle examination preparation with examination notification advisory calls and preliminary findings advisory calls arriving on FINRA's unannounced examination scheduling calendar, prepare broker-dealers for FINRA annual supervisory reviews with written supervisory procedures update advisory calls clustering in November–December under Rules 3110 and 3120, and advise broker-dealers on FINRA Regulation Best Interest annual compliance obligations with Reg BI impact assessment advisory calls arriving simultaneously for all BD clients on the date FINRA publishes its annual examination priorities report — and your invoices consistently understate the FINRA supplemental document production advisory calls that arrive during the examination window, the Rule 3120 annual supervisory control report certification advisory calls that arrive in the final weeks of the year, and the Form CRS relationship summary adequacy advisory calls that arrive in the weeks following FINRA's annual report — ClaimHour was built for that gap.

Get early access