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How FINRA’s 2019 ‘Priorities Letter’ Differs from the Past

January 22, 2019

by Howard Haykin


According to FINRA CEO Robert Cook, this year's FINRA 2019 'Priorities Letter' takes a somewhat new approach - as compared to similar letters issued in the past. Here are some of the changes ....


CHANGE IN THE TITLE.   This year’s report is entitled, “2019 Annual Risk Monitoring and Examination Priorities,” to reflect a broadened scope that more explicitly includes FINRA’s priorities for risk monitoring. For 2018, the same letter was entitled, “2018 Regulatory and Examination Priorities Letter.”



FOCUS ON EMERGING ISSUES.    The 2019 ‘Priorities Letter’ focuses “… primarily on those topics that will be materially new areas of emphasis for our risk monitoring and examination programs in the coming year.” And unlike previous Priorities Letters, FINRA does not repeat topics that have been mainstays of FINRA’s attention over the years. The new sharper focus on emerging issues should help member firms better determine whether those issues are relevant to their businesses and how they should be addressed.



UPCOMING TARGETED REGULATORY RESPONSES.    In 2019, FINRA expects to implement targeted regulatory responses to address specific risk and compliance issues in a variety of ways. FINRA will hold several conferences to foster compliance in the industry – including a repeat of its recent RegTech conference that provided firms with insights on how technology is being used to strengthen firms’ compliance programs. FINRA will also continue to enhance its market surveillance to incorporate new data and address new market practices, while continuing its retrospective rule review process to assess whether a FINRA rule or rule set is meeting its intended purpose and doing so in an efficient fashion.



IMPROVING THE OPERATIONS OF ITS REGULATORY PROGRAMS.    Having fully integrated its enforcement programs, FINRA has now launched a transformation of its risk monitoring and examination programs to integrate them into a single more effective, efficient and consistent program. By providing a single point of accountability for all firm examinations, FINRA seeks to avoid duplicative regulation while it conducts examinations that are more tailored to firms’ business models and risks.



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