Risk Control Assessment Frequently Asked Questions (FAQ)

  1. What is the Risk Control Assessment (RCA)?
  2. How do I access the survey?
  3. Is my firm's data secure?
  4. What if my firm does not receive the survey?
  5. Who at the firm is responsible for responding to the RCA?
  6. How long should the RCA take to complete?
  7. How will the responses be used?
  8. What happens if my firm doesn't complete the survey?
  9. Will FINRA spend extra time when examining my firm because we didn't complete the survey?
  10. Why doesn't FINRA already have this information?
  11. What feedback did FINRA receive from firms that participated in the 2014 RCA and also had a sales practice cycle exam in 2014?
  12. What changes have been made to the 2015 RCA?
  13. Does the RCA contain questions that relate to specific rules or compliance issues?
  14. What is the best way to answer questions when the available response options don't completely describe or could lead to a potential misinterpretation of my firm's business?
  15. The pre-selected sections listed on the Introduction page are not reflective of the material aspects of my overall business. What should I do?
  16. Should all potential business activities and or products sold be disclosed even if they are not material to the overall business?
  17. How should we answer questions that could have multiple interpretations?
  18. For firms with affiliates, what scope of business should be included in survey responses?
  19. I am unable to obtain the exact break down of my firm's revenue by brokerage business or investment banking activity. What should I do?
  20. What if I don't know the answer to a question, or I don't know how to answer it?
  21. Can I amend or revise the RCA after it has been submitted?

1. What is the Risk Control Assessment (RCA)?
The RCA is an annual survey FINRA sends to firms to collect information about the firm's business model and activities, products and services, client types and counterparties; and the underlying risks associated with its business model. We use the information collected to inform our risk-based surveillance and examination programs, with the goal of streamlining examinations.
2. How do I access the survey?
Each firm’s executive representative will receive an email on or about June 22, 2015, with a unique link to the survey. Individuals who serve as executive representative to multiple firms will receive multiple emails, each listing the name and BD number for the firm for which the survey is intended, along with the link to that firm's survey. More information, including how to complete the survey, is included in the instructions.
Alternatively, you can download the survey in Adobe PDF format if you experience difficulties accessing the online version (visit the Resources section of the main RCA page to use the PDF version). Please note that all questions marked with an asterisk require responses. As the PDF version does not allow for dynamic skip logic, you will see instructions embedded throughout the survey prompting you to skip certain questions that would not pertain to your firm. When responding to the survey using the PDF version, please make sure to save your responses and email the completed survey as an attachment to RCA@finra.org.
3. Is my firm's data secure?
The 2015 RCA is administered through CVENT, a Web-based third-party survey application. Your data and other private information is encrypted and transmitted via SSL technology. CVENT is Payment Card Industry (PCI) compliant.
4. What if my firm does not receive the survey?
The emails containing your firm's unique survey link will be sent from RCA@finra.org. Some firewall rules and Internet security may block messages from CVENT. If your firm has this level of security, please have your IT department grant access to www.cvent.com and allow all of its sub-domains.
It is also possible that your firm's network automatically sent the RCA message to a spam or junk folder. Please check the spam or junk folder of your mailbox and look for the email with the subject "2015 FINRA Risk Control Assessment" from RCA@finra.org. If you still cannot find it, please email RCA@finra.org.
5. Who at the firm is responsible for responding to the RCA?
The firm's executive representative should serve as the primary point of contact for the RCA. Depending on the firm's size and nature of its business, the executive representative may need to identify others who can respond to the survey. The survey can be saved and the link can be forwarded to others within the firm to help with this process. If multiple contributors will be responding within the firm, only one person should edit the survey at a time to avoid inadvertently overwriting responses.
6. How long should the RCA take to complete?
The RCA survey content is dynamically built based on the responses given to an initial set of questions about the firm's business model. Firms with a simple business model will complete a shorter survey. Firms that are engaged in multiple business lines will complete a longer survey. As a result, the total time commitment required to complete the survey will vary. Nonetheless, the 2015 survey is comparable in length to the 2014 survey, so we anticipate that it will take approximately the same time to complete.
7. How will the responses be used?
FINRA will use the results of the RCA to better understand the specific business models of individual member firms, the risks attendant in those business models, and the controls intended to manage those risks. We will also use this information to benchmark controls and get a better sense of industry-leading practices as they relate to risk and controls. FINRA will use this information to enhance the quality of our regulatory programs—particularly our surveillance and on-site examinations.
8. What happens if my firm doesn't complete the survey?
This is a voluntary survey. If your firm does not participate, your firm will not suffer any negative consequences. However FINRA will need to follow traditional, more time-consuming examination methods to gain a complete understanding of your firm's business model, attendant risks and controls prior to commencing an examination, and will need to gather and assess more documents and information during the course of the examination.
9. Will FINRA spend extra time when examining my firm because we didn't complete the survey?
In most instances, examinations will take longer to complete since the examiners will plan and arrive onsite at your firm without the benefit of critical information needed to complete a risk-based assessment upon which the scope of the examination is based. Feedback from firms that participated in previous RCA surveys and had subsequent examinations was that examiners were better prepared, the examinations were more targeted and the processes streamlined.
10. Why doesn't FINRA already have this information?
FINRA does not capture and maintain the type of information across all member firms that the survey seeks. Moreover, business model, product and service offering, and risk control processes change over time.
11. What feedback did FINRA receive from firms that participated in the 2014 RCA and also had a sales practice cycle exam in 2014?
Respondents generally characterized the overall impact of the RCA on their examination experience as positive. Specifically, the feedback was that their subsequent sales practice cycle exam was more streamlined, that examiners arrived on-site with a better understanding of the firm's business, and that the focus of the examinations was more targeted and less cumbersome.
12. What changes have been made to the 2015 RCA?
The 2015 RCA generally follows the 2014 RCA framework, but has been further streamlined to target key business areas. This was accomplished by utilizing updated revenue data from firms' Supplemental Statement of Income (SSOI) filings to drive the survey sections to which firms will be asked to respond. Therefore, firms only need to complete survey sections that represent material aspects of their overall business. Additional enhancements include more opportunities to provide optional comments where available answer choices do not necessarily fit, and an improved print functionality to allow for a single-click print option at the end of the survey, allowing respondents to print all of their responses at once.
13. Does the RCA contain questions that relate to specific rules or compliance issues?
No. The survey does not seek to test for compliance with specific rules. The survey is focused, instead, on improving FINRA's understanding of the business models of individual firms.
14. What is the best way to answer questions when the available response options don't completely describe or could lead to a potential misinterpretation of my firm's business?
Use your judgment to choose the best answer. The results of this analysis will not be used to try to "catch" firms, nor are the questions designed to trick respondents. FINRA is seeking to better understand the businesses in which your firm is materially engaged. In this regard, firms should use their best judgment and select the answer choice that is the closest match. Firms can also use the comments section that has been provided with many questions to explain further if necessary.
15. The pre-selected sections listed on the Introduction page are not reflective of the material aspects of my overall business. What should I do?
The pre-selected survey sections are driven by non-zero revenue line items as reported in firms' Supplemental Statement of Income (SSOI) filings from the last 12 months. You are encouraged to select additional business areas (i.e. survey sections) on the Introduction page of the 2015 RCA if they represent a material aspect of your overall business. Alternatively, you are requested to please de-select any pre-selected business line if it does not represent a material aspect of your overall business.
16. Should all potential business activities and or products sold be disclosed even if they are not material to the overall business?
No. We are interested in responses regarding business activities that represent a material component of your overall business. If these activities are not a regular part of your business or are not material, they should not be disclosed.
17. How should we answer questions that could have multiple interpretations?
Although we've taken every effort to use common financial services industry terms, you may identify words or phrases that you feel are open to interpretation. In all cases, we mean the commonly accepted uses of terms. As a general rule, use your best judgment and experience, considering interpretations from the perspective of the financial services industry.
18. For firms with affiliates, what scope of business should be included in survey responses?
The RCA focuses on the business of the broker-dealer, including businesses conducted as part of the legal entity that houses the broker-dealer. In this regard, if, for example, the same legal entity is registered as both a broker-dealer and investment adviser (commonly referred to as a "dual registrant"), complete the RCA questions from the perspective of both brokerage and advisory activities. Alternatively, if the broker-dealer is not a dual registrant but affiliated with an investment adviser that is registered through a separate legal entity, you should not complete the RCA based on the activities of the investment adviser.
19. I am unable to obtain the exact break down of my firm's revenue by brokerage business or investment banking activity. What should I do?
For questions in the survey that ask you to enter the approximate percentage of revenue for different business lines, please provide your best estimate rounded to the nearest whole number. Please see the RCA Instructions for additional guidance.
20. What if I don't know the answer to a question, or I don't know how to answer it?
Use your best judgment; and if you feel that your selection does not fully capture the nature of your business, elaborate in the comments section.
21. Can I amend or revise the RCA after it has been submitted?
It is not possible to re-open the survey to make changes to your firm's responses after the survey has been submitted. However, if you discover a material inaccuracy in your submission, please contact the FINRA RCA team, and we will make sure that the survey properly reflects your views.
If you need any additional help, please contact the FINRA RCA team.