Enhancing Enforcement

FINRA is enhancing the enforcement function to better serve our self-regulatory mission of protecting investors, safeguarding market integrity, and supporting vibrant capital markets in which everyone can invest with confidence. We are committed to sharing our progress as part of FINRA Forward, including how we build on improvements already underway and how we draw on recommendations from a report by outside experts.

As an SRO, FINRA prioritizes empowering member firms to achieve effective compliance up front and supporting quick remediation of issues with actionable information, training, tools and feedback. This support includes investing heavily in data and tools to bolster member firms’ compliance functions. For example, FINRA provides curated views of its market surveillance output and other regulatory data back to its member firms in the form of “report cards.” This information helps members identify and address potential compliance problems. We also publish an annual Regulatory Oversight Report that provides member firms with insight into findings from FINRA’s regulatory operations that can be used in supporting their own compliance programs. 

Similarly, FINRA works to identify emerging risks early so that firms can address them before regulatory action is required. Among other measures, we offer a Rapid Remediation Program that notifies member firms when we see certain potential issues so that firms can quickly address and remediate the issue outside of the enforcement program. FINRA also provides information to firms about fraud and cybersecurity issues that may require timely action. 

Further information about FINRA’s support for member firm compliance is in the FINRA Forward one-year progress report.

Key Enforcement Program Enhancements

Last updated: June 30, 2026

Management, Governance, and Oversight

• Expanded involvement of FINRA’s CEO in enforcement’s internal operations and decision-making to support overall governance of the enforcement program and help ensure that outcomes are aligned with the guiding principles and objectives for the program.
   
• Enhanced oversight of the enforcement program by FINRA’s Board of Governors through more structured briefings and discussions regarding issues arising in the program.
   
• Consolidated FINRA’s Member Supervision, Market Oversight, and Enforcement functions into a single unified Regulatory Operations department as part of a strategic realignment to optimize operations, enhance organizational efficiency, and strengthen capabilities. 
   
• Enhanced operations by creating 11 Enforcement staff specialization areas, ensuring complex matters are assigned to personnel with specialized knowledge and expertise while improving consistency and efficiency across similar cases.
  
   

Due Process and Fairness

• Offer an introductory meeting upon referral of a matter to enforcement during which FINRA staff will outline areas of focus and provide an overview of the process. Member firms can ask questions or voice concerns, as well as provide their perspectives regarding the referral and areas of focus. 
   
• At the conclusion of fact-finding, offer a meeting for enforcement staff to share investigative findings and underlying evidence with members, and provide them with the opportunity to present their perspectives and any contrary or additional information. 
   
• Require enforcement staff to provide status updates to potential respondents at least every 90 days. 
   
• Utilize an internal tool developed for FINRA staff to help support consistent communication with potential respondents. 
   
• Use updated template for internal authorization memoranda to explicitly require a description of precedent and any deviations from precedent.
   
• Implemented enhancements to the Wells process, including:
  • Extending the Wells response period to 30 calendar days absent exigent circumstances to allow more time for meaningful submissions.
     
  • Eliminating page limits on Wells submissions.
     
  • Instructing staff to accommodate reasonable extension requests and to avoid initiating Wells processes during major holidays.
     
  • Formalizing the process for enforcement staff to conduct post-Wells meetings with respondents to discuss their submissions and explaining if there has been a decision to proceed with an enforcement action.
     
  • Welcoming post-Wells meetings with enforcement leadership and the firm to ensure that enforcement has considered relevant facts and legal standards.
    
     

Information Requests and Testimony

• Launched organizational guidance and training on requesting information from member firms and associated persons, including for information requests under FINRA Rule 8210, establishing a uniform approach and a manager approval protocol for requests and a pathway for challenges by respondents.
   
• Instituted a procedure whereby, in non-exigent circumstances, enforcement staff reach out to firms and their counsel before issuing an information request under FINRA Rule 8210 to provide firms with the opportunity to clarify the scope and expectations and to ask questions.
   
• Provided enhanced guidance to staff on attending on-the-record testimony (OTR).
   
• Instituted safeguards to remind OTR participants of the means to access exhibits and transcripts.
  
   

Other Enhancements

• Provide respondents with the opportunity for engagement prior to Enforcement issuing a cautionary action letter.
   
• Use updated internal procedures to explicitly state that FINRA’s Sanctions Guidelines apply to settled matters and will incorporate this into the Enforcement Manual when published.
   
• Continued to develop and enhance staff training on relevant industry topics and areas.
   

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