Supervisory system for communications

The supervisory system for communications requirement means you must maintain written supervisory procedures that govern which communication channels your firm permits, how those channels are monitored and reviewed, and how issues escalate to compliance for resolution. To operationalize it fast, inventory channels, set supervisory owners and review rules per channel, document escalation workflows, and retain evidence that supervision happens.

Key takeaways:

• You need written procedures that cover all business-related communication channels, not just email.
• Your procedures must be operational: clear ownership, review triggers, escalation paths, and recordkeeping expectations.
• Your exam readiness depends on evidence: supervisory reviews performed, exceptions handled, and updates made as channels change.

A “supervisory system for communications requirement” becomes real for a CCO the day a rep uses an unapproved channel, a supervisor can’t show evidence of review, or an examiner asks for the firm’s escalation workflow and gets a vague narrative instead of procedures plus logs. FINRA’s baseline expectation here is simple in concept: maintain supervisory procedures governing communication channels. Your job is to translate that sentence into operating discipline across platforms, teams, and third parties.

This requirement sits at the intersection of communications rules, supervision obligations, and books-and-records duties. In practice, most breakdowns happen in the seams: marketing uses a new collaboration tool; a desk adopts SMS with clients; a third party hosts archived content; a supervisor “reviews” communications informally with no retained evidence. The fix is not a new tool by itself. The fix is a supervisory design that is written down, channel-specific, enforced through access controls and training, and proven through review evidence and exception tracking.

This page gives you requirement-level implementation guidance you can assign to owners and track to closure, with artifacts you can hand to exam teams.

Regulatory text

Regulatory excerpt (baseline requirement): “Maintain supervisory procedures governing communication channels.” ¹

What the operator must do

You must maintain written supervisory procedures that define:

• Which communication channels are permitted or prohibited for business communications.
• How the firm supervises those channels (review method, frequency triggers, sampling logic if used, and supervisory accountability).
• How communications are retained and retrievable as required under recordkeeping obligations (tie your procedures to your retention program). ²
• How supervision integrates into your broader supervisory system, including escalation and follow-up. ³

Practical reading: FINRA is looking for a supervisory system you can explain, execute, and evidence. If you can’t show how a message in a given channel is governed, supervised, and retained, your supervisory procedures are incomplete for that channel.

Plain-English interpretation

Maintain a living set of written procedures that cover every business communication pathway your associated persons use (or could use) to communicate with clients, prospects, counterparties, or the public. The procedures must assign supervision responsibilities, describe the review approach by channel, and define escalation steps when issues appear. They also must align with recordkeeping requirements for business records and communications. ²

Who it applies to (entity and operational context)

Applies to: FINRA member broker-dealers and their associated persons in the scope of firm business communications. ³

Operational contexts that routinely fall in scope:

• Retail and institutional client communications (email, chat, messaging, social).
• Marketing and advertising review processes (including drafts, approvals, and publishing workflows). ¹
• Internal channels used to discuss client matters, orders, recommendations, performance, fees, and complaints.
• Communications conducted through third parties (archiving vendors, social publishing tools, CRM messaging features) where supervision and retention responsibilities still sit with the firm. ²

What you actually need to do (step-by-step)

Step 1: Inventory all communication channels (including “shadow” channels)

Create a Communications Channel Register that lists, at minimum:

• Channel name (e.g., corporate email, mobile SMS, Teams chat, social platform DMs).
• Business uses allowed (client outreach, service, marketing, internal coordination).
• User populations (who can access).
• Approval status (approved, restricted, prohibited).
• Capture/retention method and owner. ²

Operator note: Include “features inside tools” (DMs, comments, in-app messaging) because exam findings often come from ungoverned sub-channels.

Step 2: Define channel-specific supervisory procedures (don’t write one generic policy)

For each approved channel, document:

• Supervisory owner: named role(s) responsible for review and follow-up. ³
• What gets reviewed: retail correspondence, institutional communications, marketing content, public appearances as relevant to your business model. ¹
• How review occurs: pre-use approval where required (common for certain marketing content), post-use review, risk-based sampling criteria, lexicon/keyword alerts where used, and how exceptions are dispositioned.
• Escalation workflow: when a supervisor escalates to Compliance, Legal, HR, or the business; expected documentation at each step.

Deliverable: a Written Supervisory Procedures (WSP) module titled “Communications Supervision” with a section per channel.

Step 3: Wire the procedures into access control and onboarding

Procedures without enforcement fail fast. Align HR/IT and supervision with:

• Approved-channel access: only provision approved tools to users; restrict or disable unapproved channels where feasible.
• Bring-your-own-device and mobile controls: define whether business texting is allowed and under what conditions.
• Attestation: require associated persons to attest they will use approved channels and route business communications accordingly.

This step supports your supervisory system obligation by making it harder to create unsupervised communications paths. ³

Step 4: Implement supervisory review execution and evidence capture

Set up a repeatable operating rhythm:

• Supervisors perform reviews consistent with the procedure.
• Compliance conducts oversight (quality checks, trend analysis, and remediation tracking). ³
• All reviews produce retained evidence: review logs, exception tickets, approvals, and corrective actions.

Minimum viable approach: a standardized Supervisory Review Log template used across departments with channel, period, reviewer, population/sampling approach, findings, and disposition.

Step 5: Define and test escalation workflows

Document escalation steps that are actually used:

• What constitutes an escalation event (customer complaint signals, promissory language, exaggerated claims, off-channel communications, missing approvals).
• Time-to-respond expectations (set your own internal SLAs; they are guidance, not regulatory facts).
• Who owns the final disposition and documentation.
• When training, heightened supervision, or disciplinary action is required. ³

Run tabletop tests using realistic scenarios (e.g., rep sends performance claim via an unapproved channel; marketing posts without approval).

Step 6: Align communications supervision with recordkeeping and retrieval

Map each channel to:

• Retention method (archive system, export process, third-party capture).
• Retrieval process for exams, litigation holds, and internal investigations.
• Data ownership and access rights, including third-party responsibilities. ²

Exam readiness check: If you cannot retrieve a representative set of communications for a defined period from a channel, your supervisory procedure is not operational for that channel.

Step 7: Keep it current through change management

Add a “communications channel change” gate to:

• New tool requests and renewals
• Marketing platform changes
• Mobile policy changes
• M&A integration

Update the Channel Register and WSP module as part of the change ticket closure.

Required evidence and artifacts to retain

Build an evidence set you can produce quickly:

Governance and design

• Communications Channel Register (approved/restricted/prohibited status)
• Communications Supervision WSP module and revision history ³
• Role-based supervision matrix (who reviews what, by channel)

Operational proof

• Supervisory review logs (by supervisor, date range, channel)
• Samples reviewed and annotations (or system audit trails)
• Escalation tickets and dispositions (root cause, corrective actions)
• Training completion records and attestations

Recordkeeping

• Archive configuration summaries and data-flow diagrams
• Retrieval test results (what you pulled, from where, by whom) ²
• Third-party contracts/SOWs covering capture, retention, and access support

Common exam/audit questions and hangups

Expect these, and prepare answer packets:

1. “Show me your written procedures for each communication channel.” A single generic policy triggers follow-ups. ³
2. “How do you supervise new or emerging channels?” Examiners look for change management and governance artifacts.
3. “Who reviews, how often, and how do you evidence review?” Bring logs plus examples of findings and escalations. ³
4. “How do you ensure retention and retrieval?” Provide retrieval test evidence and archiving design. ²
5. “How do you supervise marketing communications?” Tie to your advertising review workflow. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
WSP says “all communications are reviewed” with no method	Examiners ask “how,” “by whom,” and “show me”	Add channel-by-channel review procedures, sampling rules, and evidence requirements 3
Only email is in scope	Business shifts to chat/SMS/social	Maintain a Channel Register and update it through change control
Escalation is informal	No consistent outcomes; weak audit trail	Use a ticketed workflow with defined disposition categories and documentation steps
Recordkeeping is assumed to be the archive vendor’s job	The firm remains accountable for retention and retrieval	Document retention mapping and perform periodic retrieval tests 2
Supervisors “review” but keep no proof	You can’t demonstrate supervision occurred	Require review logs and system audit trails; QC them 3

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list case examples. Operationally, weaknesses here usually create two risk outcomes: (1) business communications occur in places you cannot supervise, and (2) you cannot evidence supervision and retention during an exam, investigation, or dispute. Both conditions increase regulatory, litigation, and reputational exposure under your supervision and recordkeeping obligations. ⁴

Practical 30/60/90-day execution plan

Days 0–30: Establish visibility and minimum control

• Assign an executive owner (CCO or delegated supervision owner) and working group (Compliance, IT, Supervision, Marketing).
• Build the Communications Channel Register (include owners and approval status).
• Draft or refresh the Communications Supervision WSP module with at least the top channels used in client-facing roles. ³
• Implement a standard Supervisory Review Log template and require use starting immediately.

Daydream fit: Use Daydream to track channel owners, map procedures to evidence requests, and run a repeatable review checklist by channel without losing artifacts across inboxes.

Days 31–60: Operationalize supervision and escalation

• Implement channel-specific review workflows (who reviews what; how exceptions are escalated).
• Stand up ticketing for escalations and document dispositions.
• Train supervisors and associated persons on approved channels and documentation expectations.
• Run your first QA review: select completed supervisory reviews, confirm evidence quality, and remediate gaps. ³

Days 61–90: Prove retention, retrieval, and change management

• Map retention and retrieval per channel; confirm the archive/capture method is working. ²
• Perform retrieval tests for each approved channel and retain results.
• Add a formal “new communications channel approval” step to IT/security procurement and marketing tech changes.
• Publish metrics internally (qualitative is fine): volume reviewed, exceptions found, time-to-disposition, training completion status.

Frequently Asked Questions

Do we need separate procedures for each tool (Teams, Slack, SMS), or can we write one policy?

Write one governing policy plus channel-specific procedures inside the WSP module. Examiners usually want to see how supervision works per channel, including ownership, review method, and escalation steps. ³

If a channel is prohibited, do we still need to address it in our supervisory system?

Yes. Document the prohibition, how you enforce it (access controls, monitoring, attestations), and what happens if someone uses it anyway. That turns a prohibition into an enforceable supervisory control. ³

How do we show evidence that supervisors actually reviewed communications?

Keep supervisory review logs and system audit trails that tie a reviewer to a defined population or sample, date range, and documented findings/disposition. Evidence needs to be retained and retrievable as part of your books and records program. ⁴

Does FINRA require pre-approval of every message?

The baseline requirement here is to maintain supervisory procedures governing channels, not a blanket mandate for pre-approval of all messages. Use a risk-based approach and apply pre-use approval where your business and advertising review obligations call for it. ¹

What about communications handled by a third party (archiving provider or social tool)?

Treat third-party tooling as part of your control environment: document responsibilities, confirm retention and retrieval capability, and keep evidence of testing. The firm still needs to produce records and demonstrate supervision. ²

How often should we update the channel inventory and WSP?

Update it whenever you add, change, or retire a communications channel, and after any review finding that shows the procedure is no longer accurate. Tie updates to change management so “new tool” cannot go live without supervision and retention mapped. ³

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. FINRA Rule 2210

2. FINRA Rule 4511

3. FINRA Rule 3110

4. FINRA Rule 3110; Source: FINRA Rule 4511