The Investment Industry Regulatory Authority of Canada identified priority areas of focus for its examination of members during 2015. (IIROC is a Canadian self-regulatory organization somewhat similar to the Financial Industry Regulatory Authority in the United States. It oversees all debt and equity markets in Canada, as well as all investment brokers and dealers.) Among other areas likely to be examined are firms’ cybersecurity, outsourcing practices, policies and procedures to prevent manipulative and deceptive trading practices; controls around electronic trading systems (including detection and prohibition of wash trades) and third party direct market access; and general business conduct compliance (e.g., use of social media, conflicts of issue and supervision). In connection with its 2014 reviews, IIROC noted that its examiners “continue to observe written internal control policies that are inadequate, in that they inaccurately or insufficiently describe the policies and procedures in effect” at the member. In these cases, claimed IIROC, the procedures solely incorporate by rote the minimum requirements set forth in applicable regulations, “with little substantive description of processes specific to the individual [member], no description of who is responsible for performing the procedures, or how the firm evidences performance and supervision.” Earlier this year, both FINRA and the Securities and Exchange Commission identified their priorities in 2015 examinations.