2024 SEC Examination Priorities Report: Broker-Dealers

U.S. Securities and Exchange Commission (SEC) Division of Examinations (EXAMS or Division) issued its annual examination priorities, which, for the first time, was published at the start of the SEC’s fiscal year to “better inform investors and registrants of key risks, trends, and examination topics” the Division intends to focus on in the coming year.

As related to Broker-Dealers, the 2024 Examination Priorities include:

  • Crypto assets and new technology

  • Security, resilience, and systems integrity for registrants and markets,

  • Anti-money-laundering (AML) for broker-dealers and other financial institutions, specifically including compliance with Office of Foreign Asset Control (OFAC) sanctions (including for advisers);

  • Recommended products, including complex, high-cost, illiquid, proprietary, or microcap securities;

  • Adequacy of Written Supervisory Procedures (WSPs);

  • Financial controls and related policies and procedures;

    Reg BI and Form CRS

    • Recommendations with regard to products, investment strategies, and account types

    • Form CRS, including the relationships and services that it offers to retail customers, fees and costs, conflicts of interest, and disciplinary history;

    • Conflicts of interest mitigation and avoidance procedures;

    • Processes for reviewing reasonably available alternatives

    • Factors considered in light of the investor’s investment profile, including investment goals and account characteristics

    • Obligations to file Form CRS with the SEC and deliver it to retail customers

Ref: https://www.sec.gov/files/2024-exam-priorities.pdf

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