After review, FINRA determined that it will leave in place a rule requiring registrants to participate in an annual compliance meeting ("ACM") at least once a year.
FINRA Rule 3110(a)(7) and the related Supplementary Material .04 ("SM .04") will remain in their current form. FINRA summarized several "key themes" of its assessment, and observed that market participants:
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view the ACM as an important measure in fostering compliance;
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requested additional guidance on (i) how an ACM should be conducted and (ii) topics that should be covered in an ACM; and
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would like ACM and Firm Element Continuing Education ("CE") requirements to be streamlined in order to "avoid duplication" and lessen the burden on firms.
FINRA reported that (i) 76 percent of respondents viewed the ACM as an important compliance measure, (ii) SM .04 provides information on how an ACM should be conducted and is intended to provide flexibility to firms, and (iii) it would not be possible to provide an "exhaustive list" of topics that should be covered in an ACM. In addition, FINRA stated that it is assessing ways to coordinate the ACM requirement with CE requirements.
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