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Auditors Looking Closely at SEC17a-13 Workflows

The SEC 17a-13 workflows are getting additional SEC and auditor attention due to the GameStop and Reddit activity over the past quarter.

The regulators believe that many firms will have multiple open and past due positions because of the amount of naked short selling and other securities lending activities. This means your internal auditors will most likely be looking a little closer at your current SEC 17a-13 and SEC 17a-5 policies and procedures.

You will be asked to demonstrate that you are …

· Complying with industry books and records retention rules (SEC 17a-3)

· Storing your records in a write once – read many times (WORM) environment (Sec 17a-4 / FINRA 4511)

· Performing your oversight responsibilities (FINRA 3110a - Supervision)

· Maintaining and reviewing your written Policies and Procedures (FINRA 3110b - Written Procedures)

· Updating your supervisory controls process to account for changing market conditions (FINRA 3120 – Supervision Controls)

If you have concerned about your answer to any of these questions, reach out to Loffa and we can put your mind and career at ease.

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