RIA Glossary / Annual Compliance & Filings

Written Supervisory Procedures (WSPs)

Quick Answer
Written Supervisory Procedures (WSPs) are the internal policies an investment adviser adopts to ensure the firm and its personnel comply with securities laws — covering areas like trading, advertising, recordkeeping, and personal conduct. Every registered adviser is required to have them.
Reviewed by Sam Carter, Director of Registration Services
Last reviewed September 26, 2026

What Are Written Supervisory Procedures (WSPs)?

WSPs translate regulatory requirements into the specific practices a firm actually follows day to day — who reviews client communications, how personal trading is monitored, how the firm handles custody or billing, and what happens when a violation occurs. Generic, boilerplate WSPs copied from a template without adapting them to the firm’s actual business are a common examination finding, since regulators expect the procedures to reflect the firm’s real operations, not a generic industry template.

The Chief Compliance Officer is typically responsible for maintaining and testing WSPs through the annual compliance review, updating them as the firm’s business or applicable rules change.

Why it Matters

Having WSPs on file isn’t enough — examiners test whether the firm’s actual practices match what the WSPs describe, so procedures that don’t reflect real operations are a red flag rather than a safeguard.

Frequently Asked Questions

Can I use a template for my WSPs?

A template can be a starting point, but it needs to be customized to reflect your firm’s specific business model, size, and practices to hold up in an exam.

How often should WSPs be updated?

At least annually as part of the compliance review, and promptly whenever the firm’s business practices or applicable rules change.
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