Around June 1, 2016, active FINRA member firms should have received an email asking them to take part in an individualized Risk Control Assessment Survey (“RCA Survey” or just simply “RCA”). The deadline for the RCA survey this year is Wednesday, July 20, 2016.
But what, exactly, is the RCA Survey?
FINRA utilizes the RCA survey to collect information from member firms about the risks associated with: the firm’s activities, the firm’s business model, the products and services the firm sells, and the types of clients and counterparties the firm deals with. FINRA uses this information to better understand the risks and controls within individual member firms. FINRA also utilizes the information to modify its risk-based examination and surveillance program: to benchmark controls and to get a better sense of industry-leading risks and control practices.
The RCA survey isn’t mandatory, but FINRA does recommend it be completed. Firms that complete the RCA generally have a more streamlined examination process, since they have already provided FINRA with a lot of the necessary information. This means FINRA examiners spend less time onsite than they would otherwise. The RCA also better prepares examiners to focus on firm-specific risk.
For 2016, FINRA has streamlined the RCA survey to make it easier to complete and to ensure focus on key business areas. The RCA survey now incorporates pre-filled data for member firms that completed the 2015 RCA. It also uses updated revenue data from the firm’s most recent Supplemental Statement of Income (SSOI) filing to determine which survey sections the firm should fill out. If the pre-selected sections don’t reflect the material aspects of a firm, the firm may select additional business areas to fill out. The firm may also de-select any area that doesn’t apply.
The amount of time it takes to fill out the RCA survey depends on the size of a firm and the complexity of its business model. A small firm with a simple business model will have a much shorter survey than a large firm engaged in multiple business lines. The primary point of contact between the firm and FINRA for the RCA should be the firm’s executive representative. The executive representative is allowed to delegate actually completing the survey to others within the firm. However, FINRA recommends that only one person at a time edit the RCA to avoid accidentally overwriting responses.
More information about the RCA survey may be found at the RCA reminder on the FINRA website and at FINRA’s Instructions for Completing the RCA. If you have any questions, you can call the FINRA Gateway Call Center at 301-869-6699, or contact the FINRA RCA team online.
The RCA survey link is sent from RCA@finra.org. If you believe you were supposed to receive an email but didn’t, check your email spam folder, and make sure messages from CVENT can get past your firewall. If you still can’t find the email, you can email RCA@finra.org for assistance.