The U.S. Financial Industry Regulatory Authority (FINRA) released its 2017 Regulation and Examination Priorities letter on January 5, 2017. Alan Wolper, Co-Chair of Ulmer’s Financial Services Practice, is quoted in an article written for Thomson Reuters’ Regulatory Intelligence that focuses on FINRA’s priorities in 2017.
Addressing the fact that FINRA’s priorities letter made no mention of “culture” in 2017, Mr. Wolper stated: “Culture of compliance is, in my view, the sum of a bunch of other parts, and those parts are generally capable of being objectively considered. The sum, on the other hand, is much less subject to definitions and yardsticks. Like the Justice Potter Stewart’s famous quote regarding obscene material – ‘I know it when I see it’ – perhaps that is how FINRA will gauge culture of compliance going forward, as opposed to trying to articulate a standard, or even a definition.”