
Dan Brecher
Counsel
212-286-0747 dbrecher@sh-law.comCounsel
212-286-0747 dbrecher@sh-law.comThe Financial Industry Regulatory Authority (FINRA) recently published its 2016 Regulatory and Examination Priorities Letter. For firms under FINRA’s purview, the document provides useful insight into where the organization plans to devote its resources.
Of particular note for 2016, FINRA will specifically focus on firm culture, which it notes has “a profound influence on how a firm conducts its business and manages its conflicts of interest.”
In assessing whether a firm has a “culture of compliance,” FINRA’s letter explains that it will look at five key indicators:
Supervision, risk management and controls remain top priorities for FINRA. In 2016, FINRA plans to specifically address four compliance areas where it has “observed repeated concerns that affect firms’ business conduct and the integrity of the markets.” They are:
Lastly, liquidity will remain a top area of focus in 2016. According to FINRA, it plans to review the adequacy of firms’ contingency funding plans in light of their business models. In its letter, FINRA points to Regulatory Notice 15-33, in which it advised that firms should “rigorously evaluate their liquidity needs related to both marketwide and idiosyncratic stresses, develop contingency plans so that they have sufficient liquidity to weather those stresses, and conduct stress tests and other reviews to evaluate the effectiveness of their contingency plans.”
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