# Written Supervisory Procedures: Why Generic Language Fails

FINRA examiners cite WSPs for vague language, missing platforms, and undefined review frequencies. Here's what compliant WSP language uses.

Source: https://commacompliance.com/post/wsps-off-channel-communications-generic-language-fails
Last updated: 2026-04-28

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When FINRA examiners find off-channel violations, they almost always find a second problem underneath it: the firm's Written Supervisory Procedures (WSPs) said something like "employees should avoid using unapproved messaging platforms where possible."

Nobody actually believes that sentence is doing your firm any good.

## Vague Language doesn't Meet FINRA's Supervision Rule

[FINRA Rule 3110](https://www.finra.org/rules-guidance/rulebooks/finra-rules/3110) requires every member firm to establish and maintain a system of supervision , including written procedures, "reasonably designed to achieve compliance" with applicable securities laws and regulations.

Your WSPs must do more than acknowledge problems exist. They must describe:

- **Which platforms** are subject to the policy
- **How messages are captured or prohibited** - not just which are "approved"
- **Who is responsible** for monitoring and review, by role or title
- **How often** review happens, in specific terms
- **What happens** when a violation is found — escalation path and consequences

## Enforcement Consequences

Generic WSP language isn't just a documentation problem. It's what allows other violations to compound.

When FINRA examiners find off-channel violations, they look at the WSPs. If the WSPs are vague, the firm faces two citations instead of one: failure to supervise *and* inadequate written procedures. The [May 2025 FINRA action against Network 1 Financial](/post/finra-fine-may-2025) is a recent example where the firm's failure to supervise off-channel communications was compounded by the absence of mechanisms to monitor the channels being used.

The firms that fare best in examinations are the ones whose WSPs describe, in specific terms, exactly what they do. That specificity is what makes a procedure "reasonably designed" under Rule 3110(b).

## Action Items

1. Pull your current WSP section on off-channel communications
2. Search for the five killer words, and rewrite any sentence that contains them
3. Describe how each platform is captured and supervised. For platforms that don't play nicely with standard archiving tools — WhatsApp, WeChat, Signal — your WSP needs to explain specifically how you're solving that problem.
4. Name the responsible person by role, with a defined review frequency
5. Define the escalation path for violations, including timeline

For a full pre-exam checklist, see the [SEC/FINRA Exam-Ready Checklist](/regulations/exam-ready-checklist).