While this FINRA Notice relates to the scope of a single exemption from TRACE reporting, it's worth noting that FINRA included TRACE reporting deficiencies in its December 2018 . These deficiencies included late and inaccurate TRACE reports, use of the wrong identifiers in transactions with affiliates, and deficiencies in firms' written supervisory procedures for TRACE reporting. Firms should thus consider reviewing their TRACE reporting procedures for compliance with applicable…
This year's letter focuses on "materially new priorities" and aspects of regular areas of examination that FINRA has not addressed in prior letters. This year's letter was expanded to address FINRA's areas of focus for risk monitoring as well as examinations. Some of the topics included in the 2019 letter reflect recent regulatory developments (e.g., FinCEN's new CDD Rule and FINRA's new disclosure requirements on fixed income securities, which both went into effect in 2018). Others…
Many of the measures included in the Interpretive Notice reflect good control practices that firms already may have in place to safeguard investor funds and pool assets, and ensure the accuracy of financial statements provided to investors. However, the Interpretive Notice contains a number of specific requirements, and firms should adjust their existing procedures where necessary. In particular, firms should consider the following points in reviewing current practices in light of…
In light of the regulatory focus on cybersecurity, firms should pay close attention to ISSP requirements, including the amendments proposed by the NFA. Firms should also be mindful of the requirement to address ISSP requirements as part of their NFA annual self-examination reviews.
The individual to whom supervisory responsibility is assigned must be mindful not only of the written contents of the ISSP, but also of the obligations to determine that the ISSP is reasonably…
Recent Articles & Comments
While this FINRA Notice relates to the scope of a single exemption from TRACE reporting, it's worth noting that FINRA included TRACE reporting deficiencies in its December 2018 . These deficiencies included late and inaccurate TRACE reports, use of the wrong identifiers in transactions with affiliates, and deficiencies in firms' written supervisory procedures for TRACE reporting. Firms should thus consider reviewing their TRACE reporting procedures for compliance with applicable…
This year's letter focuses on "materially new priorities" and aspects of regular areas of examination that FINRA has not addressed in prior letters. This year's letter was expanded to address FINRA's areas of focus for risk monitoring as well as examinations. Some of the topics included in the 2019 letter reflect recent regulatory developments (e.g., FinCEN's new CDD Rule and FINRA's new disclosure requirements on fixed income securities, which both went into effect in 2018). Others…
Many of the measures included in the Interpretive Notice reflect good control practices that firms already may have in place to safeguard investor funds and pool assets, and ensure the accuracy of financial statements provided to investors. However, the Interpretive Notice contains a number of specific requirements, and firms should adjust their existing procedures where necessary. In particular, firms should consider the following points in reviewing current practices in light of…
In light of the regulatory focus on cybersecurity, firms should pay close attention to ISSP requirements, including the amendments proposed by the NFA. Firms should also be mindful of the requirement to address ISSP requirements as part of their NFA annual self-examination reviews.
The individual to whom supervisory responsibility is assigned must be mindful not only of the written contents of the ISSP, but also of the obligations to determine that the ISSP is reasonably…