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FINRA 2022 Exam Report Spotlight: Communications with the Public

It came as no surprise that FINRA’s 2022 Examination and Risk Monitoring Program Report highlighted communications with the public as a continued area of focus.  The primary theme across this focus area relates to the sufficiency of internal processes, procedures, and controls.  As FINRA has done with other areas, the…

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SEC and FINRA Spotlight Net Capital Requirements and Financial Management Practices

The SEC recently published its 2022 Examination Priorities Letter on the heels of FINRA issuing its 2022 Examination and Risk Monitoring Program Report.  One of many areas of common focus is financial management, and more specifically, net capital requirements and safekeeping of funds and securities.  The SEC, for example, reminded…

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FINRA Reminds CCOs About Potential Supervisory Liability

FINRA recently published Regulatory Notice 22-10 reminding firms of the scope of Rule 3110 (Supervision) and the potential liability of Chief Compliance Officers for failure to reasonably discharge supervisory responsibilities delegated to them. FINRA recognizes that compliance and supervision are distinct roles that carry different obligations.  FINRA has said that…

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