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Experienced, Independent Review of Your Branch Office Network
The regulatory framework for remote inspections continues to evolve. FINRA's Remote Inspections Pilot Program currently allows participating broker-dealers to inspect certain offices and locations remotely, provided the firm and location meet the pilot's eligibility conditions and the firm has documented a risk assessment supporting remote inspection. Although FINRA's Board of Governors has approved a proposal to make the program permanent, further action through the SEC rulemaking process is required. DFP Partners works with clients to develop an appropriate inspection approach while remaining attentive to changes in the applicable regulatory requirements. Either way, we have you covered.
A strong branch office inspection program provides valuable insight into how a firm's supervisory procedures are being implemented across its locations. It can identify weaknesses in existing controls, inconsistent practices, and risks that may not be apparent through routine monitoring.
DFP Partners conducts on-site, remote, and hybrid branch office inspections for Broker-Dealers (BDs) and Registered Investment Advisers (RIAs). Our experienced compliance professionals work directly with your home office and branch personnel to evaluate supervisory practices, assess adherence to the firm's written supervisory procedures, review relevant recordkeeping practices, and provide objective findings and recommendations.
An effective inspection begins with an understanding of the risks associated with the office being reviewed. Our team considers relevant customer complaints, prior inspection findings, exception and surveillance reports, products and services offered, and how supervisory responsibilities are assigned and exercised. This information helps establish an appropriately focused inspection. We work with each firm’s existing supervisory processes and technology to conduct on-site, remote, or hybrid reviews, as permitted by applicable requirements.
Our inspection teams include former regulators and chief compliance officers with extensive experience evaluating supervisory and compliance programs. Through document reviews, personnel interviews, analysis of questionnaire responses, and on-site visits when appropriate, we examine office operations, recordkeeping practices, and adherence to the firm’s written procedures.
Each inspection results in a documented assessment identifying findings, potential supervisory concerns, and recommended corrective actions. Our professionals maintain regular communication with the firm’s compliance team throughout the engagement, helping ensure that findings receive appropriate attention and that the inspection process remains consistent across the branch network.
FINRA's branch office inspection requirements do not apply to standalone investment advisers. SEC-registered advisers, however, must maintain compliance programs under Advisers Act Rule 206(4)-7 that address the risks associated with their operations, including the supervision of personnel working across multiple locations. Many advisers incorporate periodic branch office reviews into those programs. DFP Partners conducts these reviews on-site, remotely, or through a combination of both, based on the adviser's supervisory procedures, business activities, and risk profile.
DFP Partners also has extensive experience serving dually registered firms and hybrid advisory arrangements, where brokerage and advisory activities may be conducted by the same individuals but subject to different regulatory requirements and supervisory procedures. We tailor our inspections to each firm's organizational structure, reviewing the applicable procedures of both the broker-dealer and investment adviser, evaluating how supervisory responsibilities are allocated, and identifying potential gaps or inconsistencies between the two compliance programs.
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FINRA's Remote Inspections Pilot Program, established under Rule 3110.18, remains in effect through June 30, 2027. Its final period, Pilot Year 4, runs from January 1 through June 30, 2027. Participating firms may inspect eligible offices and locations remotely when a documented risk assessment supports that approach, subject to the program's supervisory, documentation, and reporting requirements. Firms that do not participate in the pilot must continue conducting their required branch and office inspections on-site.
Firms already participating in the pilot will automatically continue into Pilot Year 4 unless they elect to withdraw by December 27, 2026. Eligible firms that are not currently participating may also elect to join the program by that date.
In June of 2026, FINRA's Board of Governors approved a proposal to make the Remote Inspections Pilot Program permanent. However, Board approval is only one step in the rulemaking process. As of October 13, 2026, the proposal has not been filed with the SEC. FINRA's latest regulatory policy agenda anticipates filing in the fourth quarter of 2026.
At the same meeting, FINRA's Board approved a companion proposal that would extend the presumptive inspection cycle for non-branch locations, simplify the treatment of different types of residential locations, and modify certain eligibility restrictions for Residential Supervisory Locations (RSLs). That proposal also awaits SEC filing.
FINRA is separately pursuing a broader modernization of its branch office supervision rules, with additional industry engagement expected in 2027.
These developments may change how firms approach branch office inspections. Until new rules become effective, however, firms must continue to satisfy their existing inspection and supervisory obligations.
FINRA resources: Remote Inspections Pilot Program | Regulatory Policy Agenda
Explore our brochure to learn more about our inspection process and how DFP Partners can support your firm.