FINRA Rule 4370 Update: What Changed in the Business Continuity Requirements
FINRA issued a regulatory notice clarifying broker-dealer obligations under Rule 4370. Three elements now carry stricter documentation expectations.
Analysis of CFPB, FinCEN, OCC, FINRA, FDIC, and state regulator updates. Written for the compliance officer who needs to know which controls to update, not just that something changed.
FINRA issued a regulatory notice clarifying broker-dealer obligations under Rule 4370. Three elements now carry stricter documentation expectations.
The median team reads 7 agency sources weekly. Most do it manually. Here is what the workflow looks like and where it breaks.
The revisions tighten expectations around transaction monitoring calibration documentation and customer risk rating methodology.
CFPB examiners return to the same two Reg E error resolution gaps across exam cycles: incorrect clock-start dates and provisional credit calculation errors. Here is where those gaps form.
The CDD rule at 31 CFR 1010.230 has five distinct control components. Here is how they work in practice and where they interact with the CTA beneficial ownership framework.
State requirements diverge on surety bond amounts, reporting timelines, and permissible investment rules. We document the most common drift points.
The hardest part of automated tracking is having a control library structured so obligation text can be matched against specific control identifiers.
The CFPB released its supervisory examination priorities for Q4 2025. Seven areas where internal controls commonly lag written policy.
Three recurring control gaps in how broker-dealers document best interest analysis for complex products.
Structured change summaries with obligation-level breakdowns, and confidence scores for each control mapping.
The new performance tests require more granular data collection. We mapped the 11 new data fields to existing CRA controls.
Before Regloom, tracking regulatory changes meant a shared spreadsheet, three email subscriptions, and a Friday morning reading block.