Finra Exam Priorities to Focus on Best Execution, Cyber, Digital Technology

Finra in its 2019 Risk Monitoring and Examination Priorities Letter focuses on emerging areas not articulated in prior years, including online distribution platforms and RegTech. The organization says it will continue to review and monitor firms’ compliance with areas such as: investor suitability determinations; firms’ outside business activities and private securities transactions; private placements; communications with the public; anti-money laundering; best execution; fraud, insider trading and market manipulation; net capital and customer protection; trade and order reporting; data quality and governance; recordkeeping, risk management and supervision related to these and other areas. Finra will also continue to review the adequacy of firms’ cybersecurity programs to protect sensitive information. With respect to best execution, Finra cites concerns regarding “firms failing to use reasonable diligence to assure that their customer order flow is directed to the best market” given certain conditions and said it will review how firms make their best execution decisions.