“Building on our work in 2017, a top priority for FINRA will continue to be identifying high-risk firms and individual brokers and mitigating the potential risks that they can pose to investors.

FINRA will focus on firms’ hiring and supervisory practices for high-risk brokers, including, for example, firms’ remote supervision arrangements; supervision of point-of-sale activities, including individual broker accountability when using joint rep codes; and branch inspection programs.

FINRA reminds firms of their existing obligation to adopt and implement tailored heightened supervisory procedures under FINRA Rule 3110 (Supervision) for high-risk individuals."

- 2018 FINRA Regulatory and Examination Priorities Letter
Regulators continue to focus on firm culture, including individual conduct and sales practices. Do you have the right tools in place?


Among the greatest challenges faced by financial services firms is the ability to readily identify potential risk among the firm’s employee and registered populations before it causes reputational harm. For mid-sized to large firms that population can number in the hundreds to thousands, exacerbating the oversight task. The inability to bring together the aggregate of compliance and other data to identify red flags that warrant immediate attention is core to the challenge.

Because compliance requirements are broad and originate from multiple sources, providing employees with a clear view of their compliance-related obligations, and the prescribed timeframe, is also a significant challenge. Failure to deliver this information in a concise, timely manner can lead to significant non-compliance risk and employee dissatisfaction.

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