The 2021 Report on FINRA’s Examination and Risk Monitoring Program is designed to provide broker-dealers with important information that highlights the regulator’s priorities and annual insights regarding the scope and content of their upcoming examinations. The Report also identifies key areas each broker-dealer should consider as they assess the effectiveness of their firm’s compliance program…. READ MORE
Since FINRA began publishing its annual examination priorities letter in 2006, each year cybersecurity and the protection of customer information have been identified as a top priority. The 2021 Report on FINRA’s Examination and Risk Monitoring Programs is no exception. As evidence of its concerns about cybersecurity risk, FINRA has hired a number of individuals… READ MORE
For years, FINRA has been encouraging its members to take a risk-based approach to exams and compliance. This year, FINRA has released a new, consolidated annual report to help firms improve their risk and compliance programs. Yes, this report is longer than previous exam priorities letters, and yes it has a different format, but there… READ MORE
In FINRA’s Notice to Members 20-31, members are asked to consider incorporating into their Consolidated Audit Trail (CAT) supervisory system “Daily review of the CAT Reporter Portal to: identify late trades.” While the FINRA CAT portal provides a count of events which were “Accepted Late,” it does not identify what constitutes an Accepted Late trade…. READ MORE
The Market Access Rule (Rule 15c3-5) remains on FINRA’s priority list – they have provided guidance on the rule and initiated enforcement actions against firms struggling to adhere to it. Oyster Consulting often works with clients after regulators have found issues with their Market Access program. It’s in your firm’s best interest to take a proactive look… READ MORE
When I was a regulator, we would meet each week to discuss the cases being considered for Enforcement referrals. It was surprising how often the same types of cases would come before us. These were not always headline grabbing, but they were avoidable items that came up over and over again. I thought it might… READ MORE
In the past few weeks, the industry has been given additional guidance on how CAT reporting will be monitored by the regulatory body and the SROs. We were introduced to a new acronym, CMRWG, which is the Cross-Market Regulation Working Group. The CMRWG was recently formed to reduce unnecessary duplication in enforcement efforts. SROs have… READ MORE