A 2024 FINRA regulatory settlement asserts that FINRA only first discovered a member firm's violations in a 2021 cycle examination. Apparently, the firm's written supervisory procedures were inadequate from its 1998 approval as a member all the way up  to 2021. Or so that's the logical inference. If each FINRA member firm is supposedly examined about every four or so years, shouldn't the self-regulatory-organization have looked at the member's WSPs something like at least six times over the 24-year span set out above? Doesn't FINRA bear some of the liability for not timely bringing any deficiencies to its member's attention? Not surprisingly, none of this made its way into the AWC settlement document.

• FINRA only first approved MMA as a new member firm in 1998 -- ten years after the OBA Rule was promulgated; and those same ten years covered the period when FINRA's Supervision Rule 3110 also was in force.
  
  
• In 1998, when FINRA approved MMA as a new member, that approval was supposed to be predicated upon any new firm demonstrating that it had implemented a reasonable supervisory system repleted with a set of Written Supervisory Procedures (the "WSPs"), which were supposedly submitted to FINRA and approved as a condition precedent to final membership approval.
  
  
• In 1998, MMA's WSPs should have addressed the firms oversight of both OBA and PST -- that would have been a prerequisite to obtaining new-member approval.  Only in 2021, however, did FINRA discover that MMA "had no written procedures requiring it to evaluate whether OBAs should be characterized as outside securities activities subject to the requirements of FINRA Rule 3280. The firm also lacked written procedures requiring its review and evaluation of disclosed OBAs to be documented"?