The FINRA annual compliance meeting is required by FINRA Rule 3110(a)(7). Actually, the rule requires that broker-dealers evidence the attendance (participation) of each registered representative and registered principal at an annual “interview or meeting conducted by persons designated by the member at which compliance matters relevant to the activities” of the attendees are discussed.

The supplementary material in Rule 3110.04 provides that the annual compliance meeting may be conducted in person or by other means (on-demand webcast, video conference, interactive classroom setting, telephone, or other electronic means). However, for those using these methods, FINRA requires that there is a method of ensuring that the attendee was present for the entire meeting (unique user ID and password with a platform that tracks time spent on the presentation, or click-as-you go confirmations). FINRA will also require a completed attestation by the attendee at the end of a webcast or other electronic presentation. FINRA also requires that attendees are able to ask questions at the end of the presentation and receive timely answers to those questions.

Each year, FINRA publishes a Risk Monitoring and Examination Priorities Letter. That letter outlines FINRA’s concerns that year, and these are often areas of examiner focus during examinations. Many broker-dealers offer training to associated persons on these priorities, sometimes at the FINRA annual compliance meeting. Examples of topics include:

• • Non-traded REIT compliance

• • L-share variable annuity suitability

• • High frequency trading

• Outside business activities rule
• Private securities transactions
• Hunting for yield – suitability
• Exchange traded products (ETNs and ETFs)
• Securities backed lending

If you are interested in delivering these or any other topics, please don’t hesitate to make inquiry of FirstMark.

FINRA Rule 3310(e) requires ongoing training in the area of anti-money laundering (AML). Many broker-dealers utilize online training courses, like FINRA’s Online Learning. In other cases, an in-person session makes sense.