Correct Success: FINRA 2021 Exam Results and Priorities

FINRA 2021 Exam Results and Priorities | Burr & Forman

On February 1, 2021, the Monetary Trade Regulatory Authority (“FINRA”) launched its “Report on FINRA’s Threat Monitoring and Examination Actions.” The Report combines two of FINRA’s long-standing studies: (a) the retrospective Report of Examination Findings from the prior yr; with (b) its forward-looking Examination Priorities Letter.

The brand new format is extra user-friendly for supervision and compliance professionals than the prior studies, setting out for every matter:

Regulatory Obligation with quotation to related guidelines;
Associated Concerns, formatted as questions companies ought to ask themselves;
Examination Findings and Efficient Practices, calling out the nice and the dangerous FINRA present in its prior yr’s examinations; and
Further Sources, containing citations to associated steering.

All through, shaded packing containers name consideration to numerous Rising Points, for instance:

AML and Monetary Crime Dangers deal with issuers in restricted jurisdictions (e.g., China), along with microcap and SPAC dangers.
Exterior Enterprise Actions dangers notes reporting obligations in reference to Registered Representatives who take PPP loans.
Social media platforms, together with the “gamification” of buying and selling
Focused Examinations on zero fee dangers and disclosures.

In previous years, FINRA has addressed points associated to Supervision and Senior Traders individually. The brand new Report weaves them into discussions of different matters.

The broad classes of points addressed within the Report are:

Agency Operations