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We are conducting a comprehensive self-evaluation and organizational improvement initiative called FINRA360. The objective of this effort, which CEO Robert Cook launched in early 2017, is to ensure that FINRA is operating as the most effective self-regulatory organization (SRO) it can be, working to protect investors and promote market integrity in a manner that supports strong and vibrant capital markets.


"FINRA360 provides a process for carefully considered—but ambitious—changes and improvements throughout FINRA."

–FINRA President and CEO Robert W. Cook

In April 2018, FINRA published a comprehensive FINRA360 Progress Report summarizing the significant operational and regulatory changes FINRA has made in the first year of its ongoing FINRA360 organizational review.

We are examining a range of topics and have begun making several changes to become a more effective, efficient regulator including:

Financial Guiding Principles

In January 2018, FINRA published its FINRA’s 2018 Financial Guiding Principles. The additional transparency supplements the audited annual financial report FINRA has long published and responds to feedback received during Robert Cook's listening tour. The Financial Guiding Principles set forth the key concepts and considerations that guide FINRA's longer-term financial planning and the development of our annual budget.

Report on FINRA Examination Findings

In December 2017, we published a first-ever Report on FINRA Examination Findings to educate firms and facilitate compliance. Firms have requested to learn more about what FINRA is seeing through its examination programs more broadly as a supplement to the individual reports they currently receive following any FINRA exam. The new report summarizes key examination findings from across our programs, enabling firms to use this information to strengthen their own control environment and address any potential deficiencies before their next exam.

Review of Engagement Initiatives

In response to the March 2017 Special Notice on Engagement as part of FINRA360, FINRA received a number of comments and suggestions regarding the effectiveness of communications with and education of firms, including ways in which FINRA could enhance its engagement with member firms. After careful review of the comments and suggestions received, FINRA is taking a number of actions aimed at improvements in these areas.

Consolidation of Enforcement Functions

In July 2017, we announced plans to combine two distinct enforcement teams into one unit under a new head of enforcement, Susan Schroeder, who reports directly to Robert Cook. The unified structure will improve our ability to streamline investigations and provide a more coordinated and consistent approach to oversight.

The new unit is bringing together two distinct enforcement teams within the organization – one handling disciplinary actions related to trading-based matters found through Market Regulation’s surveillance and examination programs, and the other handling cases referred from other regulatory oversight divisions including Member Regulation, Corporate Financing, the Office of Fraud Detection and Market Intelligence, and Advertising Regulation.

Innovation Outreach Initiative

In mid-2017, we established the Innovation Outreach Initiative to foster an ongoing dialogue with the securities industry that will help us better understand financial technology (FinTech) innovations and their impact on the industry. We have created a cross-departmental team led by our Office of Emerging Regulatory Issues that is responsible for carrying out the initiative and working closely with industry participants to gain real-time intelligence on FinTech issues. As part of this effort, FINRA established a new Fintech Industry Committee to facilitate discussion on FinTech developments and how FINRA’s rules and programs interact with technology innovations. FINRA will also conduct regional roundtables to provide a forum for market participants to share thoughts, ideas and concerns regarding FinTech topics. In addition, FINRA launched a new FinTech webpage and hosted a Blockchain Symposium, bringing together regulators and industry leaders to discuss the use of blockchain and the related opportunities and challenges. We are planning future FinTech-related publications and events as part of this initiative.  

Capital Formation Rule Review

In April 2017, we issued regulatory notices related to the capital formation process as part of a continuing effort to modernize our regulation of those activities while maintaining important protections for investors:

  • A request for comment on FINRA’s rules governing the participation of its member firms in capital raising.
  • A notice seeking comment on proposed amendments to rules for underwriting arrangements.

Retrospective Rule Review

FINRA launched an ongoing initiative to look periodically back at significant rules to ensure they remain relevant and appropriately designed to achieve their objectives, particularly in light of industry and market changes. FINRA encourages stakeholder engagement in the retrospective rule review process and welcomes input from FINRA member firms, investors and other interested parties regarding the rules under review as well as what other FINRA rule sets they believe should be subject to a retrospective review. In addition, FINRA staff regularly discusses with its advisory committee members which FINRA rule sets it is considering for review and seeks feedback.

FINRA undertakes this retrospective rule review process with input from and oversight by the FINRA Board. FINRA staff continues to refine the process, including tailoring the assessments to the scope and complexity of the rule or rule set under review, which can expedite the assessment phase of the process. Areas that have been or are the subject of retrospective review include:

  • communications with the public;
  • gifts, gratuities and non-cash compensation;
  • the membership application rules;
  • outside business activities and private securities transactions
  • payments for market making

FINRA has taken or is considering various actions in response to the assessments of these rule sets, such as amending rules, updating FINRA’s administration of those rules and increasing transparency through FAQs and other public vehicles.

Other Changes

Additional changes we have made in recent months include:

  • We launched a Small Firm Helpline in January 2018 to assist small broker-dealer firms that need help identifying the appropriate FINRA contact for assistance, navigating FINRA’s systems, finding online resources or have general questions regarding deadlines/effective dates for rules. The goal of the Helpline is to complement FINRA’s existing Regulatory Coordinator program by offering additional support for firms’ compliance efforts. Learn more here.
  • New FINRA rules were recently approved to streamline competency exams and facilitate opportunities for professionals seeking to enter or re-enter the securities industry. The new rules revise the current exam structure to eliminate duplicative testing and barriers to demonstrating and maintaining qualifications. The changes will make it easier for an individual with no prior securities industry experience – whether an investor, a recent college graduate or a professional seeking a second career – to take a general knowledge exam (Securities Industry Essentials) as an important first step to entering the industry. Learn more here.
  • The Securities Investor Protection Corporation (SIPC) and FINRA recently announced a new, simplified filing process.  Effective September 1, firms that currently file annual reports separately with SIPC and FINRA will file just once, using FINRA’s existing reporting portal. This is designed to ease reporting burdens and compliance costs for member firms and will also reduce inconsistent or incomplete filing of annual audited financial statements and supplementary reports. Learn more here.
  • We created a new standing committee, the Regulatory Operations Oversight Committee (ROOC), to advise and assist the Board in providing guidance and oversight to management on FINRA’s regulatory operations. The ROOC does not engage in discussions surrounding individual enforcement matters.

Contact OGC

FINRA's Office of General Counsel (OGC) staff provides broker-dealers, attorneys, registered representatives, investors and other interested parties with interpretative guidance relating to FINRA’s rules. Please see Interpreting the Rules for more information.

OGC staff contacts:
Phil Shaikun and Victoria Crane
1700 K Street, NW
Washington, DC 20006
(202) 728-8000