The supervisory control system must:
- test and verify that the supervisory procedures are reasonably designed to achieve compliance with applicable laws and regulations
- create or amend supervisory procedures where a need for change is uncovered by testing
- require the submission of an annual report:
- detailing the system of supervisory controls in place
- including the summary of test results
- identifying significant identified exceptions in those results
- highlighting additional or amended supervisory procedures created in response to the results
For firms reporting $200m or more in gross revenues in calendar year (n) a report in calendar year (n+1) must be submitted to senior management, which must include, for year (n):
- a tabulation of reports pertaining to customer complaints and internal investigations made to FINRA
- a discussion of the compliance efforts including procedures and educational programs in:
- trading and market activities
- investment banking activities
- antifraud and sales practices
- finance and operations
- supervision
- anti-money laundering
-
FINRA launches Financial Intelligence Fusion Center
Member firms can submit any threat intelligence they have via the FIFC portal and get targeted notifications.
Julie DiMauro1 min read
-
GRIP Extra: CFTC launches Innovation Task Force, digital Euro progress advances
Our in-brief roundup of notable stories from the last week.
GRIP3 min read
-
GRIP Extra: AMLA begins groundwork for direct supervision, White House unveils federal AI framework
Our in-brief roundup of notable stories from the last week.
GRIP3 min read
-
FINRA opens broad review of arbitration process
The move signals an impending reboot of an often-criticized system.
Alexander Barzacanos3 min read
-
The GRIP Files: Alexander Cohen
Alex tells us about representing clients before the SEC, FINRA, and state securities regulators and shares his experiences dealing and working with senior regulatory figures.
Jean Hurley5 min read
-
Apex and SEC battle over firm's off-channel comms settlement
Apex argues that by applying substantially less burdensome undertakings on other similarly charged firms the SEC has breached administrative law.
Julie DiMauro4 min read
-
GRIP Extra: Anthropic clashes with Pentagon, OCC proposes GENIUS Act implementation rules
Our in-brief roundup of notable stories from the last week.
GRIP2 min read
-
Tied with a bow: FINRA's gift limit goes from $100 to $300
The rule is designed to avoid conflicts of interest, which can arise when a gift is given to a client or vendor in the hope of strengthening a business relationship.
Julie DiMauro3 min read
