By John M. Jascob, J.D., LL.M. FINRA has highlighted online distribution platforms, fixed-income mark-up disclosures, and compliance with FinCEN’s Customer Due Diligence (CDD) as areas of focus for its risk monitoring and examination programs in the coming year. In its 2019 Risk Monitoring and Examination Priorities Letter, FINRA describes topics that member broker-dealers should consider as they seek to improve their compliance and risk management programs. “This year’s Priorities Letter takes a new approach by highlighting those topics that will be materially new areas of focus for our risk monitoring and examination programs in the coming year,” said FINRA CEO Robert Cook in a news release. “[W]e agree with the suggestion from many of our member firms that a sharper focus on emerging issues will help them better determine whether those issues are relevant to their businesses and how they should be addressed.” FINRA has also broadened the…
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