Happy New Year. I know it is a new year because FINRA has issued its Regulatory and Examination Priorities Letter. As with every yearly letter, it mostly covers the topics from the prior year. This year Operational and Financial Risks are clearly going to be a focus of examinations. Not surprising in the Sales Practice Section Initial Coin Offerings and Crypto-currencies have been added.

There is also a section devoted to new rules. I think the most important and the one that affects all members is the FinCEN Customer Due Diligence Rule. Firms must be in compliance with this new rule by May 11, 2018.

So what is new for 2018? I am going to call it the kinder gentler FINRA. Throughout the letter there is an attempt to thank members for making comments on new initiatives. There is also an overemphasis on how important the members are to the regulatory program. We should be glad that FINRA understands this, but it is certainly a new approach.

So perhaps FINRA examiners will approach exams with a new viewpoint. It is a new year.

As is always the case this letter should be reviewed in its entirety to make sure your compliance program is ready for review.

(C) Copy written 2018 Sharon M. Davison. Share with attribution.





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