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A sweep examination is typically initiated when a regulator identifies a systemic risk across a category of firms — not because your firm specifically flagged something. Common triggers include a new product type gaining adoption, a pattern of customer complaints in FINRA's data, or a congressional inquiry that directs examination resources.

Notice varies dramatically by exam type. A for-cause examination may arrive with zero notice — examiners show up at your door. A cycle exam typically provides 10–20 business days of advance notice via a Document Request List (DRL). Sweep exams fall in between: you may receive a letter 5–10 business days before the initial document request is due.

The practical answer: assume you are always 30 days from an exam. The firms caught off-guard are not the ones with bad compliance programs — they are the ones with good programs they never documented.

The short answer: three years for most electronic communications, six years for certain records. But the practical answer is more nuanced — and more alarming.

Under SEC Rule 17a-4 and FINRA Rule 4511, broker-dealers must preserve electronic communications — including emails, instant messages, and off-channel communications — for a minimum of three years, with the first two years in an easily accessible format.

The enforcement reality in 2024: off-channel communications (WhatsApp, personal email, iMessage used for business) resulted in over $1.8 billion in fines across 26 firms. FINRA and the SEC are not asking about emails from three years ago — they are asking why your registered representatives were discussing trades on personal devices that your archiving system never captured.

Yes — and the update must be completed before the product goes live, not after the first complaint.

Under FINRA Rule 3110 and its companion Rule 3120, your WSP must be reasonably designed to achieve compliance with applicable laws and regulations for every activity your firm conducts. A new product — whether it's a structured note, a tokenized security, or a new advisory service — represents a new activity. No WSP coverage means no supervision. No supervision is an automatic finding.

The standard exam question: "Show me your WSP section for [product] and the date it was last reviewed." If the product launched six months ago and the WSP was last updated two years ago, the examiner already has their finding.