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The document explains regulatory obligations under SEC Regulation Best Interest and FINRA Rule 3110, detailing how compliance sets policies and rationales while supervision verifies adherence through reviews and approvals. It clarifies the chain of supervision, Registered Principal responsibilities, and key definitions, and highlights the importance of understanding both the procedure’s wording and the underlying policy spirit.",{"@graph":63,"@context":123},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":36,"@type":70,"position":76},"https://docshare.wps.com/template/forms/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/harbour-wsp-effective-written-supervisory-procedures-updated-july-9-2026/278050/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/harbour-wsp-effective-written-supervisory-procedures-updated-july-9-2026/278050.png","ImageObject",442,249,{"name":88,"@type":89},"Mali","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-23","2026-09-15",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",8,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115,119],{"name":106,"@type":107,"acceptedAnswer":108},"What regulatory obligations do Harbour Investments Written Supervisory Procedures support?","Question",{"text":109,"@type":110},"They are designed to help Harbour comply with SEC Regulation Best Interest and FINRA Rule 3110, covering obligations related to care, conflicts of interest, disclosure, and maintaining an effective supervision system.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"How do Compliance and Supervision differ at Harbour?",{"text":114,"@type":110},"Compliance defines the “what and why,” develops overall policies, and handles customer complaint reviews and regulatory investigations. Supervision verifies that Investment Professionals follow Harbour’s policies through reviews and approvals.",{"name":116,"@type":107,"acceptedAnswer":117},"Who is responsible for supervising Investment Professionals and Staff?",{"text":118,"@type":110},"Registered Principals and Home Office Principals provide primary supervision for activities as set forth in the WSPs, working closely with Compliance Officers and escalating special issues to the Chief Compliance Officer (CCO).",{"name":120,"@type":107,"acceptedAnswer":121},"What do WSP and the “spirit of the policy” mean in practice?",{"text":122,"@type":110},"WSP provides more prescriptive “how to” instructions for supervising each policy in the Compliance Manual. 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Although Harbour, as a dually registered Broker/Deal and Investment Advisor, engages in many lines of business, our primary Regulators are individual States, FINRA, and the SEC. Harbour recognizes many other legitimate regulators as well (i.e. MSRB, FCC) and have written our procedures to comply with their regulations. In addition to regulatory oversight, Harbour recognizes requirements placed on its Investment Professionals through membership of professional organizations (i.e. CFP, NASAA) Harbour has been, and will continue to be, mindful of policies and requirements placed on those organizations, and has included their recommendations when not in conflict with any of our Regulators.  \nThe relationship between Compliance and Supervision  \nThe compliance department defines the \"what and why\" and develops the overall policies for Harbour to inform Investment Professionals of what they need to do to run a compliant practice, as well as documenting the rationale to help them understand why a policy is needed. Additionally, compliance reviews and processes customer complaints, and responds to regulatory investigations. Compliance helps ensure adequate supervision is taking place throughout Harbour's day-to-day business activities.  \nThe act of Supervision is the process of verifying that Investment Professionals are complying with Harbour's compliance policies. This verification is completed through reviews, (i.e., Trade, Email) and approvals (i.e., New Account Applications, Marketing) .  \nThe goal of Compliance and Supervision is to ensure that Harbour, including all associated persons, can fulfill our Regulatory Obligations.  \nWhy do we need Written Supervisory Procedures?  \nSEC Regulation Best Interest requires broker-dealers to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with the following obligations: care, conflict of interest, disclosure, and compliance. When recommending a type  \nof investment account, transaction, or investment strategy, an investment professional must actin the best interest of the client at the time the recommendation is made, taking into consideration their investment profile and other relevant factors, such as the potential risks, rewards, costs, and reasonably available alternatives.  \nFINRA Rule 3110 requires each broker-dealer to establish, maintain and enforce an effective system to supervise its activities that is reasonably designed to achieve compliance with applicable securities laws and regulations. Key elements include:  \n• Establishing a supervisory system  \n• Writing comprehensive procedures  \n• Conducting self-monitoring  \n• Conducting field office inspections  \nRegistered Principals are key partners in fulfilling the requirements of Rule 3110 and SEC Regulation Best Interest by educating Investment Professionals on, and enforcing, Harbour's policies and procedures. All Registered Principals are responsible for knowing how to access these procedures and policies, as well as remaining current in their knowledge of them. Not knowing laws, rules, and policies does not relieve an individual of their responsibility to be compliant.  \nHarbour's Written Supervisory Procedures are located on Harbour's internal webpage, in the compliance section. The compliance section also provides you access to:  \n• Compliance Manual  \n• Historical Compliance Notices  \n• Approved Designations  \n• Do Not Call List  \nLetter and Spirit of the policy  \nThese procedures have been written to meet reg","cbCaijzMTx9dO1JI","https://ap.wps.com/l/cbCaijzMTx9dO1JI","pdf",1661819,238,"English","# Introduction: Written Supervisory Procedures\n## Regulatory Obligations\n## The relationship between Compliance and Supervision\n## Why do we need Written Supervisory Procedures?\n## Letter and Spirit of the policy\n## Frequently used terms\n## Supervision Overview","[{\"question\":\"What regulatory obligations do Harbour Investments Written Supervisory Procedures support?\",\"answer\":\"They are designed to help Harbour comply with SEC Regulation Best Interest and FINRA Rule 3110, covering obligations related to care, conflicts of interest, disclosure, and maintaining an effective supervision system.\"},{\"question\":\"How do Compliance and Supervision differ at Harbour?\",\"answer\":\"Compliance defines the “what and why,” develops overall policies, and handles customer complaint reviews and regulatory investigations. Supervision verifies that Investment Professionals follow Harbour’s policies through reviews and approvals.\"},{\"question\":\"Who is responsible for supervising Investment Professionals and Staff?\",\"answer\":\"Registered Principals and Home Office Principals provide primary supervision for activities as set forth in the WSPs, working closely with Compliance Officers and escalating special issues to the Chief Compliance Officer (CCO).\"},{\"question\":\"What do WSP and the “spirit of the policy” mean in practice?\",\"answer\":\"WSP provides more prescriptive “how to” instructions for supervising each policy in the Compliance Manual. The procedures must be understood by both the exact wording and the underlying policy intent, since procedures cannot cover every imaginable situation.\"}]","Harbour-WSP-Effective - Written Supervisory Procedures - Updated July 9, 2026 | PDF",1789506529,83]