Report on Use of 2025 Fine Monies

FINRA is a not-for-profit, self-regulatory organization (SRO) dedicated to promoting investor protection and market integrity in a manner that facilitates vibrant capital markets. FINRA’s regulatory functions serve to build public confidence in the financial markets. Accordingly, FINRA is committed to continuously improving its regulatory policies and programs to make them more effective and efficient. As part of its statutory mission, FINRA enforces applicable federal securities laws and regulations and FINRA’s rules, and disciplines member firms and their associated persons, including by imposing sanctions when necessary and appropriate.

FINRA prioritizes obtaining restitution for harmed customers from member firms and their associated persons, when possible. Like many SROs in the securities industry, FINRA also can impose fines on member firms or associated persons to address wrongdoing and deter future misconduct. FINRA bases fine amounts on the facts and circumstances of each case and FINRA’s Sanction Guidelines. FINRA does not target any minimum dollar amount of fines to be issued. FINRA’s operating budget assumes that zero fines are imposed, and compensation determinations are not based on fines.

FINRA’s use of fine monies is governed by FINRA’s Financial Guiding Principles (Principles), which provide transparency about how FINRA manages financial resources in fulfilling its regulatory responsibilities. FINRA’s Board of Governors (Board) reviews the Principles biennially. As the Principles describe, FINRA accounts for fine monies separately, and any use of such monies is approved separately from other expenditures by the Board or its Finance, Operations and Technology Committee (Finance Committee). The Board or Finance Committee may authorize the use of fine monies only for one of four enumerated purposes:

• capital initiatives or nonrecurring strategic expenditures that promote more effective and efficient regulatory oversight by FINRA (including leveraging technology and data in a secure manner) or that enable improved compliance by member firms;
• activities to educate investors, promote compliance by member firms through education, compliance resources or similar projects, or ensure FINRA employees are highly trained in the markets, products and businesses it regulates;
• capital initiatives required by new legal, regulatory or audit requirements; or
• replenishing reserves in years where such reserves drop below levels reasonably appropriate to preserve FINRA’s long-term ability to fund its regulatory obligations.

In accordance with the Principles, FINRA also publishes a description of the use of fine monies approved by the Board or Finance Committee during the prior year. This report describes those approved initiatives that were supported by 2025 fine monies. 

Summary

FINRA imposed $74.2 million in fines in 2025¹, and the Board determined that there were $84.9 million in fines-eligible expenditures in 2025 (i.e., expenses eligible to be funded by fine monies based on the criteria set forth above). Because the total of fines-eligible expenditures exceeded the amount of fines issued in 2025, the balance of $10.7 million was funded from FINRA’s reserves and excess operating results.

The 2025 fines-eligible expenditures fall under two broad categories that align with the purposes set forth in the Principles:

Fines-Eligible Expenditures

The fines-eligible expenditures within these categories, which are described in more detail below, furthered FINRA’s goals to implement efficient oversight programs that protect investors and safeguard the markets, including expenditures that enhance examination, investigation and disciplinary programs; improve securities industry services and systems; strengthen the ability to track and surveil trading across markets; support member firm compliance; provide regulatory-focused training for FINRA staff; and equip investors with unbiased information, tools and resources to help them make informed investment decisions. Some of these projects are ongoing, multi-year initiatives that have extended into 2026 and, in some cases, will continue into future years.

Capital Initiatives and Nonrecurring Strategic Expenditures

Enhancing FINRA’s Regulatory Operations Programs

In 2025, FINRA invested $27.7 million in several initiatives to enhance tools and systems we use for our examination, investigation, disciplinary and other regulatory operations programs. These initiatives better align FINRA resources with the risks and business practices of member firms; improve the efficiency and consistency of examinations and investigations; improve disciplinary actions case management; and better leverage data and analytics in these programs.

• Examination Program Tools—FINRA invested $10.4 million to enhance the tools and systems FINRA examiners use to manage their work efficiently. FINRA is modernizing and streamlining the exam program to achieve a more consistent, risk-based approach to exams and enhance intelligence sharing.  
• Investigations and Disciplinary Programs—FINRA invested $6.9 million to implement an analytics-driven and data-optimized standardized investigative workflow to improve transparency and efficiency, enhance case management, as well as improve the quality of data collected and enhance regulatory intelligence. Additionally, the spending includes costs to modernize and enhance the systems and tools supporting electronic submissions for the Office of Hearing Officers.
• Advanced Analytics Transformation and GenAI Integration—In 2025, FINRA invested $6.4 million in the continuing transformation of the advanced analytics program that supports various regulatory functions. The investment includes costs for the ongoing implementation of centralized data services and analytics platforms that serve as the foundation for numerous applications supporting FINRA’s regulatory programs, as well as costs to enhance its GenAI capabilities and integrate GenAI into regulatory and support functions
• Other Regulatory Operations Programs—FINRA invested $4.0 million to enhance how FINRA shares real-time regulatory intelligence, as well as establish tailored cyber risk and incident response training for member firms.

Promoting Transparency and Strengthening Regulators’ Ability to Track and Surveil Trading Across Markets

Combining data from FINRA reporting and transparency systems and the Consolidated Audit Trail (CAT), FINRA’s comprehensive surveillance program is an essential part of its work to monitor the integrity of the markets. In 2025, FINRA conducted cross-market surveillance for all trading in U.S.-listed equities and options. FINRA also conducts surveillance of the unlisted equity market and certain fixed income instruments that trade in the over-the-counter market to identify potential market manipulation or other misconduct. In 2025, FINRA allocated $19.3 million to promote transparency and strengthen monitoring of equity, option and fixed income market activity. 

• Transparency Services—In 2025, FINRA invested $10.1 million as part of a multi-year initiative to improve the Multi-Product Platform (MPP), which facilitates the collection and dissemination of transaction and quotation data across several markets—namely over-the-counter trading of listed equities, unlisted equities, corporate bonds, Treasury securities and a variety of other fixed income instruments. The investment also included costs to build the Securities Lending and Transparency Engine (SLATE) for enhanced oversight of the securities lending market and modernization of the Form 211 and Form T filing platforms.
• Surveillance—FINRA enhanced the sophisticated surveillance “patterns” we use to detect a wide variety of compliance issues and suspicious conduct across markets, enhance reviews of the results of those patterns and support rapid responses to market events. In addition, FINRA integrated its insider trading platform into the broader surveillance platform and commenced other platform-related enhancements. FINRA invested $7.1 million to update these systems.
• Other Programs—FINRA invested $2.1 million to enhance its Report Card Program for firms, including developing a dashboard that allows firms to track and visualize data, and modernize data standards. This investment also includes costs for other programs that promote transparency and strengthen surveillance of market trading activity. 

Improving Securities Industry Services and Systems

FINRA administers services and systems that serve member firms and their associated persons, and support member oversight. FINRA invested $15.3 million to enhance these services and systems in 2025.

• Advertising, Corporate Finance and Other Systems—FINRA modernized the platforms firms use to comply with advertising and corporate finance reporting rules. Additionally, FINRA enhanced its fingerprinting platform driven by Federal Bureau of Investigation requirements, enhanced the Dispute Resolution Services portal to support mobile devices and function automation, and implemented changes to allow service providers to file submissions on behalf of firms to FINRA's regulatory systems. FINRA invested $10.2 million to update or develop these systems.
• Registration and Testing System Enhancements—FINRA invested $5.1 million to enhance the Financial Professional Gateway, modernize registration and data processing functionality, and enhance tracking and management of statutory disqualification matters.

Compliance Resources, Training and Educating Investors

Supporting Member Firm Compliance

In 2025, FINRA spent $9.0 million to fund various tools and resources to support member firm compliance. 

FINRA offered virtual and in-person conferences and educational programs*, some of which were tailored to the unique business needs of FINRA member firms, including a Small Firm Conference and various Cybersecurity offerings, including tabletop exercises and workshops. In addition, FINRA offered virtual education on various regulatory topics and business line specific webinars to member firms free of cost, including FBI Cyber Threat briefings, education on identifying fraud, specific sessions focused on fixed income trading, targeted educational programming for Financial and Operations Principals (FINOPs), and a session on the SEC's amendments to Regulation S-P to help member firms prepare for compliance.

This amount also includes spending to operate the FINRA Support Center. 

*Note: The program costs include expenses net of funding received from registration fees or other revenues related to conferences and educational programs.

Regulatory-Focused Training for FINRA Staff 

FINRA continues to provide training to staff, including examiners, to ensure staff is prepared for new regulatory challenges and has the proper understanding of the current regulatory environment. In 2025, FINRA spent $8.8 million on regulatory-focused training for FINRA staff. 

Educating Investors

FINRA provides investors with unbiased information, tools and resources that can equip them to make informed decisions. In 2025, FINRA invested $4.8 million in investor education research and programs.

• FINRA Investor Education Foundation—Throughout the year, FINRA provided management oversight and program and administrative support (including investing, legal, tax and treasury) to the FINRA Investor Education Foundation to carry out its financial capability-building initiatives.** The FINRA Investor Education Foundation released the sixth wave of the National Financial Capability Study (NFCS), an expansive source of data and insights about the financial lives of U.S. adults that has been conducted every three years since 2009. It also released findings from the investor survey component of the NFCS, which takes a closer look at the attitudes, behaviors and knowledge of retail investors. The Foundation also published six new research reports, including studies on the information sources financial consumers use and the factors they find most and least important when assessing information, activities and beliefs that affect fraud victimization, and financial and health literacy as people age.
• Investor Education Programs—In 2025, FINRA continued to enhance BrokerCheck^®, including conducting an investor survey to inform future improvements. FINRA also distributed new or substantially refreshed information for retail investors, including content on a range of investment products, understanding risk tolerance, and tips for avoiding fraud risks, such as those posed by unregistered firms or individuals.

**Note: The direct program costs of the FINRA Investor Education Foundation are funded from the assets of the FINRA Investor Education Foundation, rather than from fine monies or reserves.