I am not aware of many broker-dealers that do not have, some, if not all of the operational professionals at senior levels registered. But clearly my experience did not spread across the entire industry.

In case you missed the release (Reg. Not. 11-33) while you were away on vacation, effective October 17, 2011 certain operational professionals will need to take an exam (Series 99) and become registered with FINRA. This of course means that they will become part of your registered staff and need to be supervised by a registered principal.

It is probably a good time to review your supervisory structure and written supervisory procedures.