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FINRA 2017 Exam Priorities – New Podcast

March 28, 2017

FINRA released the last in a four-part podcast series that highlights key issues from the FINRA Regulatory & Examination Priorities for 2017, sent in early January to member firms. [See Financialish, 1/4/17


In this latest podcast, FINRA addresses Market Integrity issues that FINRA examiners will likely be looking for during the coming year.


Financialish offers the following ‘Marketing Integrity’ take-aways.    FINRA examiners will be looking at …


  • ‘Cross-Market Equity Supervisor Report Card’, for possible spoofing or layering.


  • ‘Best Execution’, for automation of markets (equities and fixed income) and payment for order flow.


  • ‘FINRA Audit Trail Reporting Early Remediation Initiative’, for potential equity audit trail issues not typically detected through routine compliance sweeps and reviews. FINRA is expanding the Initiative  for Regulation NMS trade-throughs and Locked & Crossed Markets.


  • ‘Tick Size’.


  • ‘SEC’s Market Access Rule’, for control documentation and rationales, and consistent monitoring of controls implementation.


  • ‘Trading Exams’, for alt-trading systems - including disclosing to customers how they operate, as well as conflicts of interest and best execution.


  • ‘Pilot Trading Program’ rollout, for testing of smaller firms not typically subject to trading exams.


  • ‘Enhancements to FINRA”s Fixed Income Securities Surveillance Program’, for more manipulation patterns, for FI written supervisory programs (WSPs) coverage of new TRACE reporting requirements, and for data integrity programs that monitor submitted data accuracy.