The SEC exam priorities for 2024 give an essential insight into likely practices, products, and services which will be the focus of the Division of Examinations in the coming year. The priorities are those that pose emerging risks to investors or the markets, as well as examinations of core and perennial risk areas. Given the now more than $2.6bn of fines imposed for recordkeeping failures, it is fair to say that unmonitored communications channels and the incomplete capture of required records will continue to be key supervisory considerations for all U.S. financial services firms.
The focus on recordkeeping is twofold – first off the recordkeeping and obligations themselves but then also a firm’s ability to robustly and comprehensively evidence compliance with all regulatory requirements is critically dependent on upfront records capture and preservation. Only with the relevant, native context records able to be retrieved will firms be able to demonstrate that their policies and procedures are operating effectively and the business undertaken is compliant.