The demand splits into three employer shapes that share a city and do not share a statute. The first is a broker-dealer whose supervision desk is in St. Louis. FINRA Rule 3130(a) requires the member to designate, and to identify on Schedule A of Form BD, one or more principals to serve as chief compliance officer. Rule 3130(b) requires the chief executive officer, or an equivalent officer, to certify each year that the member has processes to establish, maintain, review, test, and modify written compliance policies and written supervisory procedures reasonably designed to achieve compliance with FINRA rules, MSRB rules, and the federal securities laws. The certification also states that the chief executive officer met with the chief compliance officer in the preceding 12 months. The report that evidences those processes is submitted to the board of directors and the audit committee at the earlier of their next scheduled meetings or within 45 days of the certification.
FINRA’s membership-continuance filing of 4 September 2025 for Edward D. Jones & Co., L.P., a member since 16 October 1939 and headquartered in St. Louis, states that the firm has 15,308 branches, of which 147 are offices of supervisory jurisdiction, and employs approximately 25,165 registered representatives, of whom 1,373 are registered principals, plus 21 operations professionals and 40,603 non-registered fingerprint employees. Those numbers are the firm’s, nationwide. They are not a Sartori placement count, and they are not a statement that this firm is a client. They describe the scale of a supervisory system whose chief compliance officer is designated in St. Louis. The same filing recounts a 20 December 2024 letter of acceptance, waiver, and consent in which the firm consented to restitution of $4,440,979 plus interest for failures to supervise sales-charge waivers and fee rebates, and records that FINRA staff confirmed the certification of payment on 25 June 2025. A routine examination completed in March 2025 produced a cautionary action letter on the firm’s written supervisory procedures for Consolidated Audit Trail data entry.
Missouri’s own securities order against the same firm is a separate document. Consent Order AP-25-08, dated 15 December 2025, records that Missouri was a lead state in a multi-state investigation of commissions above 5 percent of principal on certain small equity trades from 1 May 2020 through 30 April 2025. Nationwide, the order describes about 781,240 such transactions totaling $11,287,504. For Missouri-resident customers the order requires restitution of no less than $526,569.72, plus interest of 6 percent from the date of each transaction to 19 May 2025. The Enforcement Section alleged a contravention of 15 CSR 30-51.171(2)(A), the state supervision rule. A chief compliance officer hired against that file is hired to own written supervisory procedures. The person is not hired because a newspaper printed a lawyer median.
The second shape is the bank, and it is not the broker-dealer by another name. The Missouri Division of Finance’s count of 188 state-regulated banks, as of 31 December 2025, is the charter population the Division examines, together with three nondeposit trust companies. The St. Louis Fed’s 132 state member banks are the state-chartered banks that are members of the Federal Reserve System inside the Eighth District. A BSA officer at a state member bank is examined by the Fed and by the state. A BSA officer at a state nonmember bank is examined by the FDIC and by the state. A national bank in the same metro is examined by the OCC. Rule 3130 does not appoint any of those officers. Supplementary material .08 says a broker-dealer’s chief compliance officer may hold another position inside the member if the person can still discharge the chief compliance officer duties. It does not appoint that person as the BSA officer of an affiliated bank.
The third shape is a hospital system or a health plan. The statutes on that brief are HIPAA, the Anti-Kickback Statute, and the False Claims Act. The officer reports to a board committee that is reading quality, billing, and privacy, not a FINRA certification. No public table counts how many of those officers St. Louis employs. Of the 19 closed St. Louis-facing in-house searches over three years, 4 were compliance and regulatory seats. Of those 4, 2 were chief compliance officer seats at a broker-dealer, 1 was a BSA officer at a state-chartered bank, and 1 was a combined seat. That is the whole compliance slice of the 19.
Of the 36 compliance, AML, or broker-dealer supervisory counsel inside the cohort of 325, 18 said they would not take a seat that combined the FINRA chief compliance officer and the bank BSA officer. The 18 are a subset of the 36, and the 36 are a subset of the 325. A combined brief hears that answer before the scorecard is locked. The scorecard in week one, before any name is discussed, is short.
- Which officer. FINRA Rule 3130 chief compliance officer on Schedule A of Form BD, BSA officer of a named charter, healthcare compliance officer, or a combination the statutes do not treat as one job.
- Which supervisor. FINRA and the Missouri Securities Division for the broker-dealer. The Fed, the FDIC, or the OCC, plus the Missouri Division of Finance where the charter is state, for the bank. A hospital brief names the board committee, not a securities regulator.
- Who signs. Rule 3130(b): the chief executive officer certifies, and the certification records a meeting with the chief compliance officer in the preceding 12 months.
- What the report is. The certification report goes to the board and the audit committee at the earlier of their next meetings or within 45 days. A brief that skips that sentence has not described the job.
- Which number is a headcount. 29,117 is the March 2025 statewide roll. 188 is the Division’s bank count as of 31 December 2025. 437 is the St. Louis Fed’s Eighth District holding-company count in the 2025 annual report. None of those is a count of Sartori searches.