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For updates and guidance related to COVID-19 / Coronavirus, click here.

FINRA’s Continued Response to COVID-19

March 18, 2020
Volume 11


  • UPC Advisory
disciplinary actions

Disciplinary Actions


Upcoming Deadlines and Effective Dates
  • FINRA Requests for Comment

Education and Compliance Programs

Last week, FINRA’s Board of Governors met for the first time in 2020. During the meeting, the Board approved the allocation of 2019 fine monies, approved a proposal to assess fees for reporting transactions of U.S. Treasury securities to TRACE (subject to filing with the SEC), and more.

Tune in to the FINRA Unscripted podcast to hear FINRA leaders review existing and emerging regulatory topics that impact the broker-dealer industry, as well as other insights into the operations of FINRA.

On this episode, Lisa Robinson, senior director of FINRA’s Membership Application Program (MAP) Group, joins the podcast to provide an overview of the MAP Group and its important role as the gatekeeper to the broker-dealer industry. Listen to the podcast.


In light of current events related to COVID-19, the SEC’s Division of Trading and Markets has provided FINRA and the other Participants in the CAT NMS Plan with no-action relief from enforcing their CAT Compliance Rules with regard to CAT implementation deadlines against Industry Members. The Division indicates that its no-action relief applies through May 20, 2020, but could be extended. See the CAT NMS Plan Operating Committee’s letter. Separately, the SEC also issued relief that exempts the Participants from collecting or retaining certain retail customer data. See the SEC’s order.

In response to the outbreak of coronavirus disease 2019 (COVID-19), FINRA has made the following adjustments:

  • Pre-filing meetings and membership interviews for new and continuing membership applications will now be conducted via video conference. FINRA will also grant courtesy extensions on new or continuing membership applications.
  • The Office of Hearing Officers has postponed hearings of Disciplinary Proceedings scheduled through April with the exception of pending Expedited Proceedings, as they are not conducted in person.
  • All in-person arbitration and mediation proceedings scheduled through May 1, 2020, have been administratively postponed. (Note that this decision does not affect other case deadlines.)
  • FINRA is providing temporary relief for member firms from rules and requirements in a new set of Frequently Asked Questions. The relief provided does not extend beyond the identified rules and requirements.

To discuss these changes in detail, and other coronavirus-related issues, senior FINRA leaders are hosting a Small Firm Conference Call tomorrow, March 19, at 4:30 p.m. Eastern Time. Space on the call is limited, so register today!

FINRA will continue to consider additional relief or adjustments as appropriate. For all of FINRA’s latest COVID-19 updates, visit FINRA’s website.



UPC Advisory

The following UPC Advisory was published in the last week:

  • UPC #06-20 Pandemic-Related Guidance in Connection with Company-Related Action Submissions
  Disciplinary Actions

FINRA publishes disciplinary actions to remind registered representatives and firms of specific conduct that violates FINRA rules and may result in disciplinary action. FINRA posted the following disciplinary item on the website this week:

 Upcoming Deadlines and Effective Dates

FINRA Requests for Comment

FINRA’s Capital Acquisition Broker (CAB) rules provide a simplified rulebook for broker-dealers that engage only in limited capital advisory, corporate restructuring and private placement activities. FINRA is requesting comment on proposed amendments to the CAB rules, as described in Regulatory Notice 20-04, to make them more useful to CABs without reducing investor protection. The comment period expires March 30, 2020.

FINRA is requesting comment on a proposal to implement the recommendations of the CE Council regarding enhancements to the continuing education requirements for securities industry professionals. The proposal, described in Regulatory Notice 20-05, would change the: (1) Regulatory Element to provide annual training, make the content more relevant, incorporate diverse instructional formats, publicize the learning topics in advance and enhance the related management systems; (2) Firm Element to expressly recognize other training requirements, improve the guidance and resources available to firms and establish a content catalog; and (3) Continuing Education Program to enable individuals who terminate their registrations the option of maintaining their qualification by completing continuing education. The comment period expires April 20, 2020.

 Education and Compliance Programs

Registration is open for the 2020 Small Firm Conference. The event will be held on November 11–12 in Santa Monica, California, and will bring together FINRA staff and industry peers for in-depth discussions on small firms' practices. Register early to receive discounted registration rates!

Save the Date for these upcoming FINRA events:

  • FINRA Institute at Georgetown Certified Regulatory and Compliance Professional® Program – Week I | July 19–24, 2020 | Washington, DC
  • FINRA Institute at Georgetown Certified Regulatory and Compliance Professional® Program – Week II | November 15–20, 2020 | Washington, DC

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