On January 22, 2019, the Financial Industry Regulatory
Authority, Inc. ("FINRA") released its annual priorities
letter highlighting its regulatory program's points of
emphasis for the coming year. The most immediately recognizable
difference between this year's edition and previous ones is
that its traditional title, "Examination Priorities," has
been updated to include "Risk Monitoring," the process by
which the self-regulatory organization initially identifies problem
areas through surveillance, firm reporting, surveys,
questionnaires, and examination findings.
FINRA's 2019 "Risk Monitoring and Examination
Priorities Letter" (the "Letter") also discusses
three entirely new priorities: online distribution platforms, fixed
income mark-up disclosure, and regulatory technology. Finally, the
Letter lists ongoing areas of focus, and alerts firms that it will
continue to assess protocols to handle the risks posed by "bad
actors" with problematic regulatory histories.