In what has become a yearly occurrence, FINRA has notified its member firms about its intent regarding the member firms’ compliance programs. See https://www.finra.org/rules-guidance/guidance/reports/2021-finras-examination-and-risk-monitoring-program.
This year, FINRA combined its Report on Examination Findings and Observations (an analysis of prior examination results) and the Risk Monitoring and Examination Program Priorities Letter (planned areas of review) into “FINRA’s Risk Monitoring and Examination Activities Report.” This new report is 46 pages long, and very dense. It is meant to assist member firms on what they should be reviewing, analyzing, and remediating, including, but not limited to, AML; OBAs; sales and communications, specifically, Regulation BI, Form CRS, private placements and variable annuities; compliance; cybersecurity; “game-like” trading platforms; best execution and trade routing; and, of course, net capital and customer protection.
In sum, FINRA looks like it is planning a busy year, meaning member firms will be even more busy. It is strongly suggested that member firms seek seasoned securities counsel to prepare for this onslaught.