FINRA Conducts Review of Firm’s “Zero Commissions”

In a targeted examination, FINRA is seeking information on the practices of firms that charge zero commission on client trades and “the impact that not charging commissions has or will have on the Firm’s order routing.”

In this latest targeted exam, also referred to as a “sweep,” FINRA’s Market Regulation Department’s Trading & Financial Compliance Examinations Department issued a sample exam letter of the information requested. The letter is intended to elicit information about the scope of the trades on which no commission is charged, as well as information concerning how the firm makes money, whether clients understand how the firm makes money, and whether the firm’s revenue practices may be detrimental to customers; e.g., whether the firm is less focused on obtaining best execution for customers because it is more dependent on obtaining revenue through trade rebates or payments for order flow arrangements.

LOFCHIE COMMENTARY

This is actually quite a significant targeted exam letter. It has relevance well beyond those firms that have a zero commission offering. FINRA is asking very detailed questions about how the firm makes money, and how the firm’s revenue stream affects the manner in which the firm does business and treats customers.

The type of information that the letter is intended to elicit includes information that would be relevant to the completion of Form CRS that is to be provided to clients.

In short, all firms, not only those that are potential recipients of the letter, should give careful consideration to how they would answer the questions raised, and as to how those answers would look to the regulators and their customers.

CFS Monetary Measures for January 2020

Today we release CFS monetary and financial measures for January 2020. CFS Divisia M4, which is the broadest and most important measure of money, grew by 6.9% in January 2020 on a year-over-year basis versus 6.7% in December.

For Monetary and Financial Data Release Report:
http://www.centerforfinancialstability.org/amfm/Divisia_Jan20.pdf

For more information about the CFS Divisia indices and the data in Excel:
http://www.centerforfinancialstability.org/amfm_data.php

Bloomberg terminal users can access our monetary and financial statistics by any of the four options:

1) {ALLX DIVM }
2) {ECST T DIVMM4IY}
3) {ECST} –> ‘Monetary Sector’ –> ‘Money Supply’ –> Change Source in top right to ‘Center for Financial Stability’
4) {ECST S US MONEY SUPPLY} –> From source list on left, select ‘Center for Financial Stability’