As financial professionals, you understand the importance of accuracy and efficiency in your operations. However, one persistent operational challenge can significantly impact your firm’s productivity – Not in Good Order (NIGO) submissions. 

NIGOs refer to any application, form, or transaction rejected due to incomplete or inaccurate information. While seemingly minor, NIGOs can create a ripple effect of delays, frustration, potential compliance issues, and dissatisfied clients.

Many RIAs utilize an Office of Supervisory Jurisdiction (OSJ) as an effective strategy to reduce NIGO rates. 

This article examines the common causes of NIGOs and how an OSJ’s supervisory and support structure can significantly improve the accuracy and efficiency of your submissions.

Understanding the Impact of NIGOs

NIGOs can arise from a variety of factors, including:

  • Incomplete forms: Missing sections, blank data fields, or incorrect formatting can all lead to rejection.
  • Missing signatures: Incomplete signatures from clients or financial professionals can hold up the processing of important documents.
  • Inaccurate information: Typos, inconsistencies, or outdated information can raise red flags and trigger NIGO rejections.

These seemingly minor errors can have a significant impact on your operations. NIGOs can lead to:

  • Delayed processing times: Rejected submissions require rework and resubmission, causing delays for your team and clients.
  • Increased workload: Valuable time for you and your staff is diverted from serving clients to correcting and resubmitting NIGO submissions.
  • Compliance concerns: Repeated NIGOs can raise questions about your firm’s internal controls and compliance procedures.
  • Client dissatisfaction: Delays and rework caused by NIGOs can erode client trust and satisfaction.

Minimizing NIGOs is crucial for maintaining operational efficiency, client satisfaction, and potential compliance adherence. This is where an OSJ plays a vital role.

Role of OSJs in Documentation and Processing

Super OSJs act as a supervisory and support hub for many independent financial professionals. Their responsibilities encompass a range of functions that contribute to streamlining your operations and enhancing your RIA compliance program

A super OSJ can specifically intervene to improve documentation accuracy and completeness. They establish review processes for all client documentation and account opening packages. These reviews identify potential issues like missing signatures, incomplete sections, or inconsistencies in information before they reach the custodian or broker-dealer.

They keep you updated on any regulatory changes or updates to submission requirements. Additionally, they assist with proper documentation procedures and best practices for your staff, ensuring everyone involved is on the same page.

By providing these supervisory and support functions, a super OSJ can proactively assist in preventing  NIGO issues before they arise.

OSJ Strategies for Reducing NIGOs

Here are specific strategies they employ to minimize NIGO rates:

OSJs will typically implement a pre-submission review process. This might involve dedicated staff or technology solutions to examine all documentation before submission. These reviews can catch errors early, saving valuable time and frustration.

They then work with you to establish clear guidelines for completing forms, gathering signatures, and ensuring proper formatting. Consistency in preparation significantly reduces errors and NIGO rejections.

OSJs also provide ongoing training and educational resources for you and your staff on proper documentation procedures and best practices. Training can cover topics like recognizing potential NIGO pitfalls, understanding regulatory requirements, and utilizing technology solutions effectively. 

By implementing these strategies, OSJs equips you and your team with the tools and knowledge necessary to submit accurate and complete documentation from the very beginning.

Technology and Tools Used by OSJs

Technological advances and solutions are assisting RIAs, IARs, and OSJs in better managing their supervisory and support functions. Here are some of the tools commonly used:

  • Document management systems: These systems allow for the electronic storage, organization, and retrieval of client documents. This streamlines the review process for OSJs and allows easy access to past submissions for reference.
  • Electronic signature platforms: Gone are the days of chasing down physical signatures. Electronic signature platforms enable clients and financial professionals to sign documents securely and efficiently. This reduces the risk of missing signatures and expedites the entire submission process.
  • Compliance software: Staying up to date with constantly changing regulations is challenging. Compliance software can provide OSJs with current regulatory requirements and potential NIGO triggers. This can be invaluable in ensuring all submissions adhere to the latest industry standards.
  • Workflow management tools: Streamlining workflows is critical to efficiency. Workflow management tools can help OSJs track submission progress, identify bottlenecks, and ensure timely completion of all required tasks. This not only reduces NIGO risks but also improves overall operational performance.

Measuring the Success of OSJ Interventions

How do you measure the effectiveness of an OSJ’s efforts in reducing NIGO rates? Several key metrics and KPIs (Key Performance Indicators) can provide valuable insights:

NIGO rate: This is the most straightforward metric, representing the percentage of submissions rejected due to NIGO issues. A decline in the NIGO rate indicates a positive impact of the OSJ’s interventions.

Processing time: Tracking the average time to process submissions can reveal efficiency improvements. A decrease in processing time often correlates with a reduction in NIGO rates.

Client satisfaction: Ultimately, happy clients are the goal. Monitoring client satisfaction metrics provides valuable feedback on the impact of reduced NIGO rates. Less rework and faster processing times lead to a more positive client experience.

By implementing a combination of supervisory oversight, standardized procedures, staff training, and technological solutions, OSJs can significantly reduce NIGO rates. This can translate into faster processing times, reduced workload for staff, and a more satisfied client base, showcasing the tangible benefits of partnering with an OSJ.

Partner With Evolution Financial Advisors As Your OSJ

At Evolution, we understand the importance of maintaining a low NIGO rate for your practice. Our experienced team utilizes a comprehensive approach that combines industry best practices, technological solutions, and ongoing support for you and your staff.

We are a boutique Large Enterprise/OSJ in the OSAIC network. The size of our firm means that every independent financial professional we serve is extremely important to us.

By partnering with Evolution Financial Advisors as your OSJ, you benefit from:

  • A dedicated team of professionals committed to minimizing your NIGO rate.
  • A robust pre-submission review process to catch errors early.
  • Standardized procedures and ongoing training for your staff.
  • Access to the latest technology solutions to streamline submissions.
  • Measurable results that demonstrate the positive impact of our services.

Contact us today, and let us help you reduce NIGOs with our OSJ services.

Large Enterprise/OSJ
Chris Virgil

More about the author: Chris Virgil

Chris is the assistant vice president at Evolution Financial Advisors. He works to help advisors grow their businesses and gain a sense of freedom. Chris is a business and behavioral coach working with existing EFA financial professionals to create a more fulfilling practice, streamline operations, and enhance client experience.