The Financial Industry Regulatory Authority, in its 2016 exam priorities letter, identifies firm culture as its very first priority. FINRA quickly followed with an announcement on Feb. 18, 2016, of targeted examinations to review “how firms establish, communicate and implement cultural values.” FINRA now expects broker-dealers not only to have implemented a firm culture, but to have metrics by which they monitor and enforce that culture. What does FINRA mean when it talks about firm culture? How does FINRA expect firms to measure it? Is it operas plus ballets attended per capita? Do you subtract for UFC and WrestleMania matches? Is it Meryl Streep movies watched divided by Vince Vaughn?