May 25, 2020

FINRA Releases 2018 Annual Regulatory and Examinations Priorities

As it does every January, FINRA released its annual Regulatory and Examinations Priorities Letteridentifying areas of examination focus for the coming year, recurring challenges faced by firms, and possible risks impacting the financial sector. FINRA’s 2018 exam priorities for the first time identify cryptocurrencies and related initial coin offerings (ICOs). Other first-mentions include technology governance, business continuity plans, and non-purpose loans. FINRA’s highest listed priorities this year are the repeated priorities of fraud and recidivist brokers.

Protecting senior investors was a prominent part of FINRA’s Exam Priorities in 2014, 2015, 2016, and 2017. In 2018, protection of seniors was not a delineated priority issue but permeated most all other topics.

Despite the fact that FINRA has announced a more strategic use of its resources, most of the old favorites make an appearance including suitability, AML, and cybersecurity.

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About this Author

Terry Weiss, Greenberg Traurig Law Firm, Atlanta, Corporate and Finance Litigation Attorney

With nearly 30 years of practical experience, Terry R. Weiss focuses his practice on representing the securities industry in the full range of legal disputes. In that capacity, he represents broker-dealers, investment advisors, prime brokers and securities industry professionals in regulatory and enforcement matters, civil litigation and arbitrations and internal investigations.

Terry has served as lead counsel in more than 100 cases that have been tried. He and his team are experienced in taking cases through trial and being brought into...

William B. Mack, Greenberg Traurig Law Firm, New York, Finance Law Attorney

William B. Mack is part of the firm’s government affairs and financial regulatory and compliance groups. He is experienced in advising companies on regulatory and compliance matters relating to the Securities and Exchange Commission regulations, the Exchange Act, Anti-Money Laundering laws and Financial Industry Regulatory Authority (FINRA) rules.

William’s practice involves all aspects of broker-dealer regulation, including Self-Regulatory Organization (SRO) membership, supervision, employment, research, soft dollar arrangements, chaperoning of foreign broker-dealers, social media, use of foreign finders, anti-money laundering rules, and market making issues. He also provides regulatory guidance to investment banking clients in connection with securities offerings and related trading issues.

William advises firms in the FINRA new membership (NMA) and the continuing membership (CMA) processes. William assists firms to develop or amend their written supervisory procedures and compliance manuals.

Stefanie Wayco, Greenberg Traurig Law Firm, Atlanta, Corporate, Finance and Litigation Law Attorney

Stefanie M. Wayco focuses her practice on representing financial services firms, broker-dealers, securities industry professionals and others in regulatory and enforcement matters, FINRA arbitrations and internal investigations. She has wide-ranging experience with product cases, alternative investments, mutual funds and variable annuities, senior investors, Anti-Money Laundering, Bank Secrecy Act, outside business activities, privilege issues, compliance policies, supervisory policies, and standard operating procedures for financial services firms.