In a Report to Congress, the Government Accountability Office ("GAO") found that (i) SEC oversight of FINRA operations covered the 10 specified areas required by the Dodd-Frank Act and (ii) SEC internal guidance on conducting FINRA examinations followed generally accepted government auditing standards.

The GAO concluded that SEC examinations of FINRA since 2015 covered all 10 areas outlined in Dodd-Frank Section 964, including governance, funding and transparency. Some examinations went beyond Section 964, covering markets surveillance and restitution for harmed investors. The inspections focused on the following areas: "(1) code of conduct, (2) executive and employee compensation practices, (3) investment portfolio, (4) compliance resource provider program, and (5) the funding mechanism for its regulatory services agreement."

Additionally, GAO found that (i) SEC guidance used to examine FINRA ("requirements for planning, pre-fieldwork scoping, and communicating findings") was consistent with accepted government auditing standards and (ii) the Office of Compliance Inspections and Examinations program review of FINRA governance between 2015 and 2017 was in line with SEC internal guidance.

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