Ernie Kappotis:

Don Pollard:

Securities Compliance

ICG provides a broad range of compliance and regulatory services to the broker-dealer community.

Our clients have found that outsourcing certain aspects of their compliance functions is a cost effective strategy that provides access to qualified experts when needed.

ICG consultants are constantly talking with regulators and reviewing new rules and guidelines in order to stay current on SEC, FINRA and state regulator exam priorities, focus areas and new initiatives.

Whether you are in the process of starting a new firm or require services for your existing firm, such as a mock regulatory exam, assistance with branch audits, new supervisory procedures, a continuing membership application or assistance with FOCUS reports, state licensing or Central Registration Depository (CRD) registrations --->

  • You can be confident the consultant assigned to your firm will be up-to-date on the relevant issues related to broker-dealer compliance.

  • ICG’s broker-dealer clients cover a broad range of activities, including general securities, investment company products, private & institutional equity, and mergers & acquisitions.

Our Top-flight Compliance Team Is Directed By Donald R. Pollard


A designated CCO is at the heart of ICG’s service platform. The CCO is the chief architect who assesses the components needed in an engagement, either by a series of interviews and research or a comprehensive audit of the firm in its structure, needs and weaknesses. ICG offers a team of seasoned, experienced CCOs with years of experience in not only managing a major compliance department but those who have recognized the value of good relationships with regulators over the years.


ICG assists firms through the FINRA membership from beginning to end. With regulatory and industry experience offered by the professional staff at ICG, we can reduce the risk of delayed or abandoned registrations, additional work delays and costly legal issues. Unlike many of our competitors, we provide a totally customized program for our start up broker-dealer clients.


ICG will assist firms through the FINRA membership process. The regulatory and industry experience offered by the professional staff at ICG can reduce the risk of delayed or abandoned registrations, additional work delays and costly legal issues. Unlike many of our competitors, we provide a totally customized program for our start up broker-dealer clients.


The cornerstone of a firm’s compliance program is an effective set of supervisory and compliance procedures and supervisory control procedures that are reasonably designed to achieve compliance with all applicable securities laws, regulations and rules of the FINRA and MSRB. We take the time to understand the firm’s business plan and prepare policies and procedures that address each firm’s unique compliance issues. We want our clients to have a solid foundation from the beginning. Our training program during the application process also distinguishes us from our competitors.


By the time your firm receives regulatory approval, your principals and staff will have a full understanding on how to implement the required systems and procedures so that you are prepared to “hit the ground running.” You will also be better prepared for your six-month new member FINRA audit. We will prepare and file all required documents including the Form NMA for broker-dealer registration with the SEC, FINRA, MSRB and state and foreign jurisdictions.



ICG’s Branch Audit Program is a consultant-based program that provides branch compliance supervisory services to assist firms’ home offices develop and implement a branch supervisory system that should include:

  • Clear and effective supervisory structure

  • Training

  • Evidence of supervisory review

  • Follow-up of exceptions (“red flags”)

  • Monitoring effectiveness


AML Programs (Model or Customized)

ICG has developed a comprehensive program to help clients comply with their AML responsibilities.

  • ICG’s program includes:

  • A Customer Identification Program

  • A sample AML policy statement

  • AML E-Mail updating service

  • Staff time to assist in the customization process

  • Written supervisory procedures including sample client forms and red flags to assist in monitoring activity and opening accounts.

Independent AML Audits

Regulatory Audits

ICG can assist you with regulatory audits. We can review your documents and sit in on the meetings and help you manage the process from start to finish. ICG can also draft your audit response letters.



For years, under NASD Rule 3010 and NYSE Rule 342, broker dealers have been required to have supervisory systems and written supervisory procedures in place that are reasonably designed to ensure compliance with applicable rules and regulations. However, NASD Rule 3012, FINRA Rule 3130 and amended NYSE Rule 342 have raised the bar on regulatory expectations regarding supervisory and compliance systems. FINRA Rule 3130 requires every CEO of a broker dealer to certify that the broker dealer maintains a process to establish, maintain, review, test and modify written compliance and supervisory procedures.

ICG offers the following program to help firms comply with the rules. ICG’s program is based on feedback from FINRA regarding expectations for program implementation. ICG’s program…

  • Develops a list of business activities and applicable rules, regulations and internal controls for each activity;

  • Conducts a “gap analysis” of firms’ current supervisory procedures by assessing whether their procedures adequately address all applicable rules, regulations and internal policies and controls for each business activity

  • Develops new or modified procedures where material gaps in the current procedures exist;

  • Develops and implements a verification and testing plan for the firm’s’ procedures;

  • Develops a reporting model to meet the requirements of NASD Rule 3012 and FINRA Rule 3013; and

  • Creates a model that may be used to support the CEO certification and reporting requirements in future years.


Challenges for principals and compliance staff continue to grow with the recent onslaught of new rules and regulatory initiatives. In an effort to assist firms in meeting these challenges, ICG offers compliance and supervisory training in person, via conference call and via web-cast. ICG will customize programs to meet every firm’s needs.xt about your company and your services.

  • The initial Form ADV

  • Amendments to Form ADV

  • State Notice Filings

  • State Registrations for State Advisers

  • Annual Amendments

  • ICG provides investment adviser representative services, including

  • Entering adviser representatives initial Form U-4s onto IARD

  • Transitioning adviser representatives onto IARD

  • Updating Form U-4s

  • Form U-5 processing


Intersource Consulting Group (ICG) has developed a program with three (3) primary objectives: (1) To assist ICG clients in preparing for an actual regulatory examination; (2) To give ICG clients an objective assessment of their compliance program by identifying potential problem areas before they result in customer complaints or disciplinary action; and (3) To assist ICG clients in complying with their supervisory responsibility related to internal inspections.ICG’s program helps broker dealers comply with NASD Rules 3010(c) and 3012 and FINRA Rule 3130.


As a result of ICG’s active investment advisory practice, ICG sees SEC comment letters quite frequently. Consequently, ICG has a “finger on the pulse” of the latest SEC exam focus, as well as district office differences. ICG will examine your firm for compliance with SEC requirements and, if requested, issue a confidential report to management outlining ICG’s examination findings, along with recommendations for corrective action. In addition, ICG will assist in creating solutions to the issues identified in the examination.