FINRA’s 2020 Risk Monitoring and Examination Priorities Letter identifies a number of areas of focus for the examination program in the coming year.  Here we highlight particular areas of focus for capital markets practitioners:

  • Private placement retail communications and online distribution platforms:  FINRA will review how member firms use social media and other platforms in connection with private placements, as well as other traditional retail communications in connection with private placements.
  • IPO Share Sales:  FINRA will review compliance with recently amended Rules 5130 and 5131 as well as other IPO related practices.  For example, FINRA notes it may consider how member firms develop and implement IPO allocation methodologies, and how firms obtain, record, and verify customer information for individuals receiving IPO allocations.
  • LIBOR:  FINRA will seek to understand how member firms are preparing for the phase out of LIBOR in 2021.