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.