Training and attestation

The training and attestation requirement for FINRA communications supervision means you must train supervised persons on approved communication channels and their recordkeeping/advertising obligations, then capture attestations that they understand and will comply. Operationalize it by defining channel rules, assigning role-based training, running onboarding and recurring training cycles, and retaining audit-ready training and attestation evidence.

Key takeaways:

• Train every supervised person on what channels are allowed, what’s prohibited, and what must be captured as a record ¹.
• Pair training with documented attestations and keep the records in a retrievable format aligned to your books-and-records program ².
• Tie completion, exceptions, and follow-up to supervision workflows so gaps become supervisory findings, not exam surprises ³.

FINRA communications compliance breaks down in predictable places: unclear channel rules, inconsistent training across roles, and weak proof that people were actually trained. For a CCO or GRC lead, the fastest path to a defensible program is to treat training and attestation as a supervisory control that produces evidence you can hand to an examiner without reconstruction. The baseline requirement is straightforward: train personnel on communication obligations and channel restrictions ¹. The operational lift is in scope, cadence, and documentation.

This page gives requirement-level guidance you can implement quickly. It covers who needs training (and why “everyone gets the same deck” fails), how to structure the content so it maps to your policies and surveillance program, what attestations should say, and what artifacts you must retain so your program holds up under FINRA supervision and recordkeeping expectations ⁴. You’ll also get an execution plan you can run in parallel with policy updates, tooling changes (archiving and approved channels), and supervisory testing. Daydream can help you track training obligations, evidence, and exceptions as living controls rather than spreadsheet chores.

Regulatory text

Requirement (baseline): “Train personnel on communication obligations and channel restrictions.” ¹

What the operator must do

You need a repeatable program that:

1. Defines communication obligations and channel restrictions in plain language (what is permitted, what is prohibited, what requires approval, and what must be retained as a record), and
2. Trains personnel who create, approve, send, or supervise communications, and
3. Collects and retains attestations that those personnel understand and will comply, and
4. Keeps training/attestation evidence consistent with your supervision and recordkeeping controls ⁴.

This requirement sits at the intersection of:

• Content standards and oversight for communications ¹
• Supervisory systems and control design ³
• Books and records expectations for preserving evidence ²

Plain-English interpretation (what this really means)

Your firm cannot rely on policy PDFs or informal norms. You must be able to show that the people who communicate with the public (and the managers who supervise them) were trained on:

• Which channels they may use for business communications (email, approved chat, approved texting solution, etc.).
• Which channels they may not use (“off-channel” texting/messaging, personal email, unsanctioned apps).
• What counts as a business communication and how it is captured/retained.
• What requires review/approval, escalation, or pre-use filing under your internal processes.
• The consequences of violations and how to self-report issues internally.

Attestation is your proof mechanism. Training without attestation often turns into “we think they watched it.” Attestation turns it into “they acknowledged the rule and their responsibility,” which is easier to supervise and enforce.

Who it applies to

Entity scope

• FINRA member broker-dealers and their supervised persons in functions that create, distribute, approve, or supervise communications ⁵.

Operational scope (practical)

Include people in these buckets:

• Registered reps and sales staff: highest volume of client-facing messages.
• Marketing and communications: creates retail communications and campaign content.
• Supervisory principals and managers: accountable for approval workflows and exception handling ³.
• Client service, operations, and onboarding teams: often communicate account details and instructions.
• Contractors/temps with client contact or marketing support: train them if they can create or transmit business communications.
• IT and collaboration-tool admins: they implement allowed channels and retention configurations; they need the “why” and escalation paths.

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

Step 1: Write channel rules that can be trained (and tested)

Create a Communication Channels Standard (one page is fine) that lists:

• Approved channels for business communications.
• Prohibited channels and “gray areas” (personal devices, personal email, DMs).
• Whether client-initiated messages on a prohibited channel must be stopped, moved, and reported.
• Recordkeeping note: which systems archive which channels, and what to do if capture fails ².

Deliverable: version-controlled standard mapped to supervision procedures ³.

Step 2: Build role-based training modules (not one generic course)

Use short modules tied to job realities:

• All-hands module: what counts as a business communication, approved vs. prohibited channels, escalation steps.
• Rep module: real examples (scheduling, performance discussions, recommendations) and what to do if a client texts.
• Marketing module: content creation, review workflow, and “retail communication” handling aligned to your internal review standards ¹.
• Supervisor module: approving content, monitoring red flags, documenting follow-up under supervisory systems ³.

Include scenario questions. Auditors will ask how you validated understanding, not just attendance.

Step 3: Decide training triggers and cadence

Set events that automatically require training:

• New hire onboarding into a covered role.
• Role change into marketing, supervision, or client-facing duties.
• Policy update to channels, archiving, or approval process.
• Material incidents (off-channel finding, archiving outage, campaign violation).

Then set a recurring cycle (annual is common in practice as internal policy), and document why that cadence fits your communication risk profile ³.

Step 4: Add attestation language that actually covers the risk

Attestations should be specific. Include statements that the user acknowledges:

• They will use only approved channels for business communications.
• They will not conduct business via prohibited channels and will report attempts.
• They understand communications may be monitored and retained according to firm policy ².
• They know how to escalate exceptions and incidents.

Keep the attestation tied to the exact policies and standards in effect on the completion date (version references matter).

Step 5: Implement tracking, exception handling, and escalation

A training program fails when completions are not operationalized. Build a workflow:

• Automated assignment and reminders.
• Escalation to the supervisor for overdue training ³.
• Restricted access consequences for persistent non-completion (for example, removal from distribution lists or disabling certain tools, per your internal process).
• Documented exceptions (LOA, tech access issues) with compensating controls.

Daydream fits well here as the system of record for control operation: who was assigned, who completed, what evidence exists, what exceptions were approved, and what follow-up happened.

Step 6: Test the control like an examiner would

Run periodic checks:

• Sample completions against your HR roster and role assignments.
• Validate attestations are stored, searchable, and complete ².
• Confirm training content reflects current channel policy and your supervision procedures ³.
• Tie failures to corrective actions and track closure.

Required evidence and artifacts to retain

Keep artifacts in a retrievable format consistent with books and records practices ²:

Training content and governance

• Training deck/video/script with version history.
• Policy/standard references embedded in training (channel rules, escalation steps).
• Approval/ownership record (Compliance sign-off, business owner sign-off).

Completion and attestation proof

• Learner roster (name, role, department, supervisor).
• Completion logs (date/time, score if applicable, retries).
• Attestation text and user acceptance record.
• Evidence of follow-up for non-completers (emails, tickets, supervisory notes) ³.

Exceptions and incidents

• Exception register with approvals and compensating controls.
• Incident-driven retraining assignments and completion proof.

Common exam/audit questions and hangups

Expect questions framed like these:

• “Show me your approved channels and where employees are trained on them.” ¹
• “How do you ensure new hires are trained before they communicate with clients?” ³
• “How do you know training was completed by the right population, and how do you handle overdue training?” ³
• “Produce attestations for a sample of reps and their supervisors.” ²
• “What changed in training after you added a new messaging tool?” ³

Hangups that slow exams: missing historical versions of training/attestation language, inability to reconcile HR roster to training rosters, and ad hoc exception approvals without documentation.

Frequent implementation mistakes (and how to avoid them)

1. Training doesn’t match the actual channel stack. If Teams is approved but not archived, your training will create false assurance. Align training with the systems that retain records ².
2. No supervisor-specific module. Supervisors need concrete expectations for follow-up and documentation under your supervisory system ³.
3. Attestation is vague. “I agree to follow policies” is weak. Tie it to approved channels, prohibited channels, and reporting steps.
4. Population misses contractors and shared mailboxes. If they can communicate externally, include them or restrict their access.
5. Completions tracked, but not enforced. If overdue training has no consequence, it becomes optional in practice. Document escalation steps.

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. The risk remains practical and exam-driven: weak training/attestation undermines your ability to demonstrate a functioning supervisory system ³ and creates recordkeeping exposure when staff use unapproved channels that are not captured ². Training evidence is often the first artifact requested because it is a fast proxy for whether supervision is designed and operating.

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and content)

• Inventory communication channels in use (approved and “in the wild”).
• Publish a single-page channel standard with do/don’t rules and escalation path.
• Draft role-based modules and attestation language aligned to your policies ¹.
• Decide training triggers (new hire, role change, policy change, incidents).
• Stand up an evidence folder structure or Daydream control record for training, attestations, and exceptions.

Days 31–60 (rollout and evidence generation)

• Launch training for high-risk groups first: reps, marketing, supervisors.
• Collect attestations and produce a completion report by supervisor chain.
• Start overdue escalation workflow with documented follow-up ³.
• Validate record retention: can you retrieve a given rep’s attestation on demand ²?
• Log exceptions with approvals and compensating controls.

Days 61–90 (operationalize as BAU + testing)

• Expand training to remaining covered roles and contractors with access.
• Run a roster reconciliation test (HR vs. training assignments vs. completions).
• Conduct a tabletop: “client texts rep on personal phone,” test reporting and remediation steps.
• Update training based on findings and lock the next cycle into compliance calendar ownership.
• Build a metrics view for management: completion status, exceptions, retraining after incidents (no percentages required).

Frequently Asked Questions

Do I need attestations, or is training completion enough?

The requirement calls for training, but attestations give you durable proof that personnel understood channel restrictions and agreed to comply. They also strengthen supervision follow-up because the obligation is acknowledged in writing ⁴.

Who counts as “personnel” for communications training?

Treat it as anyone who creates, approves, sends, or supervises business communications, including marketing and supervisors ⁵. If a contractor can email or message clients on your behalf, include them or restrict access.

How detailed should channel restrictions be in training?

Detailed enough that a rep can decide, in the moment, whether a channel is allowed and what to do if a client uses a prohibited channel. Include examples and the escalation path, and keep the list synchronized with what your firm can actually retain as a record ².

What evidence do examiners typically ask for first?

Expect requests for training content, completion rosters, and individual attestations, then follow-up records for overdue training or exceptions ⁴. Make sure you can produce historical versions tied to dates.

How do we handle employees who are on leave or lack system access during training rollout?

Document an exception with a reason, an approval, and a plan to complete training before the person resumes covered communications. Keep the exception record with the same rigor as your training logs ².

Can Daydream replace our LMS?

Daydream typically complements an LMS by acting as the compliance system of record for the control: mapping requirements to training obligations, collecting evidence, tracking exceptions, and packaging artifacts for audits. If you keep the LMS, Daydream can store exports and approvals alongside supervisory follow-up documentation ⁴.

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; FINRA Rule 4511

5. FINRA Rule 2210; FINRA Rule 3110