S3:E2 | 2022 Report on FINRA’s Examination and Risk Monitoring Program | Compliance in Context

 

Welcome back to the Compliance in Context Podcast! On this episode of the Compliance In Context Podcast, we explore the hidden nuances and key differences in the new 2022 Report on FINRA’s Examination and Risk Monitoring Program with Susan Schroeder—former head of enforcement at FINRA and current partner at Wilmer Hale—who sits down with us to review the report and its impact on compliance professionals everywhere. In our Headlines section, we look at the recently released annual priorities issued by the SEC Division of Examinations. And finally, we’ll wrap up today’s show with another installment of History Has Your Back series where we look at the legendary kung fu martial artist, Bruce Lee, and a quote to help inspire you and provide peace of mind for the securities compliance professional. 

Show

  • Headlines

    • 1:14: Digesting the Annual Priorities from the SEC Division of Examination

 

  • Interview with Susan Schroeder

    • 7:38: Introduction & General Remarks on the 2022 FINRA Report

    • 11:27: “Reasonableness” and Testing AML Programs

    • 16:16: Tackling Cybersecurity and Technology Governance

    • 23:30: Mobile Devices and Investing

    • 32:13: How Best Execution Standards are Changing

    • 37:21: Challenges Surrounding Trusted Contact Information

 

  • History Has Your Back

    • 45:43: Using Bruce Lee’s words as inspiration to elevate our firms and provide peace of mind

Quotes

09:45: “On a really high level, my reaction to the report when I read it was that the report reflects the enormous amount of innovation and disruption that is rippling throughout the industry. Right? I think we’ve all heard a lot about new business models through fin-tech businesses for example, that are changing the way people invest. Changing the shape of investment relationships.” - Susan Schroeder 

10:20: “One of the things you can also see emerging is the fact that FINRA’s rules are not written for the way business is done today and some of their observations and some of their priorities really reflect a disconnect between rules that might be seventy years old and practices that are very 2022.” - Susan Schroeder

12:16: ““I think now though, a lot of the challenge you’ll see across the industry is that the industry has room. Right? With the proliferation of new technologies, with people doing app-based trading on their phones, you’ll see events like the Gamestop event last year where the amount of trading that is done in a single day just eclipses previous records.” - Susan Schroeder

17:02: “I think, the fact that we talk about technology governance as if it’s a known thing is already a big indicator that your firm should be worried because that is a framework to exist. Right? No one was talking about that, even, for years ago. And this notion of technology governance is that the business is obligated to supervise the technology. Right? I think it’s a new concept and one that has not been well built-out by the regulators.” - Susan Schroeder

26:57: “The mobile app gives everybody access to…real time information.  It is funny to me that there is as much concern that it is driving customer behavior when I consider it really to be a great equalizer, in providing information to people in a way a large group of investors could not have before.” - Susan Schroeder

Previous
Previous

S3:E3 | Lessons From The Front Lines - Facing the Frontier of DeFi and Crypto | Compliance in Context

Next
Next

S3:E1 | Private Fund Rule Proposals -Enhancing Investor Protections or Unnecessary Sea Change? | Compliance in Context