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Making on our work in 2017, a top rated precedence for FINRA will continue being determining high-danger companies and individual brokers and mitigating the potential threats that they can pose to investors.2 FINRA will focus on corporations’ employing and supervisory practices for high-hazard brokers, which includes, for example, firms’ distant supervision preparations; supervision of place-of-sale things to do, together with particular person broker accountability when using joint rep codes; and department inspection systems.
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Inside our examination of corporations’ compliance with SEA Rule 15c3-three, We're going to Consider no matter whether firms have implemented suitable controls and supervision to safeguard consumer property and evaluate their compliance with the precise necessities on the rule (
, whether or not they thoroughly carry out their possession or Regulate calculations). Moreover, FINRA will evaluation regardless of whether corporations sustain adequate documentation to exhibit that securities are held free of liens and encumbrances, especially for securities held at overseas custodians. FINRA will evaluation irrespective of whether corporations’ international depositories, clearing companies and custodial banking institutions are very good control destinations, like regardless of whether firms have submitted applications with the SEC for such foreign custodial arrangements.
8 If a agency’s Rule 201 guidelines and methods include things like an automatic, rules-dependent Manage to ensure compliance, FINRA expects the business to build a supervisory program to test that the Manage works correctly also to perform comprehensive supervisory reviews equally ahead of and frequently following it is operational.