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FINRA Announces Review of Higher-Risk Structured Products

May 20, 2026

Features

  • FINRA Announces Review of Higher-Risk Structured Products
    Consistent with our mission of investor protection, FINRA announced Tuesday that it will review firm practices regarding higher-risk structured products, specifically non-principal protected “worst-of” structured notes. The review will examine how firms supervise concentrations in these products, including how they comply with Regulation Best Interest and FINRA rules when their registered representatives recommend these products to investors. FINRA’s review of firm supervision for concentration in higher-risk structured products will only affect a subset of member firms. However, we encourage all firms that recommend these products to review the questions in the letter and evaluate their practices.
  • FINRA Updates Interpretations for New Intraday Margin Standards
    FINRA published Reg. Notice 26-11 announcing updated interpretations of its margin rule (FINRA Rule 4210) to provide guidance to members in implementing the new intraday margin standards. Correspondingly, FINRA is deleting all interpretations relating to the former day trading margin requirements, which the new intraday margin standards have replaced in their entirety. Also, FINRA has made available educational resources, which members can share with customers, that provide information about the new intraday margin standards and margin accounts. The new and modified interpretations are available at Interpretations of Rule 4210. The educational resources are available here:
     
  • Holiday Reminder: FINRA Market Transparency Reporting Systems 
    In observance of Memorial Day, our Market Transparency Reporting Systems will be closed on May 25. Affected applications include:
    • Alternative Display Facility (ADF)
    • Over-the-Counter Reporting Facility (ORF)
    • Trade Reporting and Compliance Engine (TRACE)
    • FINRA/Exchange Trade Reporting Facilities (TRFs)


      For more information, please review the Holiday Calendar for Market Transparency Reporting Systems, or contact FINRA Market Operations at (866) 776-0800. 

Regulatory Reminders
  • TRACE Transition to Native FIX: FINRA is transitioning from our legacy FIX Protocol platform to a new Native FIX platform for TRACE trade reporting. We anticipate retiring all TRACE legacy FIX reporting late in the fourth quarter of this year.
     
  • Rule 8210 Information Request Delivery: FINRA filed a proposed rule change with the SEC to amend Rule 8210(d) to specify that FINRA will deliver electronically its requests for information and testimony to member firms through FINRA Gateway, rather than by mail. The proposed rule change will be implemented on May 26.
     
  • Proposal to Improve Price Transparency in TRACE: FINRA filed a proposed rule change with the SEC on April 22 that would expand the existing non-member affiliate—principal transaction indicator in TRACE to also suppress certain member-to-member affiliate transactions from public dissemination. Comments are due to the SEC by May 27.
     
  • Outside Activities Proposal: The SEC instituted proceedings to determine whether to approve or disapprove our amended proposal to streamline and reduce unnecessary burdens regarding existing requirements that address the outside activities of member firms' associated persons. Comments are due to the SEC by May 27, and rebuttal comments are due to the SEC by June 10.
     
  • Proposal to Facilitate Capital Formation: The SEC on April 23 instituted proceedings to determine whether to approve or disapprove FINRA’s proposed rule changes to streamline aspects of the corporate financing process. Comments were due to the SEC by May 19, and rebuttal comments are due to the SEC by June 2.
     
  • New Intraday Margin Standards: FINRA adopted new intraday margin standards to replace in their entirety the outdated day trading margin requirements, including the day trade count requirements for designating a customer as a “pattern day trader” and the $25,000 pattern day trader minimum equity requirement. The effective date of the amendments is June 4. Members that need more time to implement the rule change will be permitted to phase in their implementation over a period of 18 months, until Oct. 20, 2027. FINRA published Reg. Notice 26-11 announcing updated interpretations of FINRA Rule 4210 (Margin Requirements) to guide members in implementing the new intraday margin standards.
     
  • Proposal to Amend Short Interest Reporting Framework: FINRA proposed amendments to our short interest reporting framework to enhance transparency and strengthen regulatory oversight of SEC Regulation SHO compliance. Comments are due to the SEC by June 8.
     
  • TRACE Reporting for BD/IAs: FINRA has amended Rule 6730 to allow firms that operate as both broker-dealers and investment advisers (BD/IAs) to report allocations of aggregate orders to multiple managed customer accounts in a single TRACE report, rather than submitting separate reports for each account allocation. The optional streamlined reporting alternative takes effect June 8.
     
  • Board of Governors Election: FINRA will hold a Board election on July 13 for a small firm seat and a large firm seat.
     
  • New Member Application: FINRA has introduced technological enhancements to the New Member Application (Form NMA). The enhanced Form NMA is now available through FINRA Gateway. The legacy version of the form will retire on July 15

Disciplinary Actions

  • FINRA fined two member firms a total of more than $1.1 million for anti-money laundering (AML) and supervisory violations related to low-priced securities transactions. Specifically, FINRA fined Pictet Overseas Inc. $610,000 for these violations concerning low-priced securities transactions, the majority of which occurred through an omnibus account held by the firm’s affiliate, along with other violations. This action comes on the heels of FINRA’s $550,000 fine against Blue Ocean ATS for similar violations. In settling these matters, Pictet and Blue Ocean consented to the entry of FINRA’s findings, without admitting or denying the charges. Reg. Notice 19-18 provides guidance to member firms regarding suspicious activity monitoring and reporting obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program). In addition, FINRA provides updated guidance and compliance training to member firms about their AML compliance obligations. The 2026 FINRA Annual Regulatory Oversight Report contains information about FINRA’s areas of concern related to AML.

     
  • FINRA publishes disciplinary actions to remind members of specific conduct that violates FINRA rules and may result in disciplinary action. The May 2026 Monthly Disciplinary Actions are available here.
Education and Compliance Programs

Webinar: AI Adoption in Practice: Implementation | May 27 | Virtual Event

Webinar: From Red Flags to Real Results: How Regulators and Firms Stop Elder Financial Exploitation | June 2 | Virtual Event

FINRA Crypto Applied Learning Program | June 2-4 | In-Person Event | Washington, DC

FINRA Certified Regulatory and Compliance Professional (CRCP)® Program Week I | July 12-17 | In-Person Event | Washington, DC

U.S. Department of the Treasury's Large Position Reporting Rules Workshop 2026 | June 26 | Virtual Event

Webinar: AI Adoption in Practice: Supervision | July 29 | Virtual Event

Financial Crimes and Cybersecurity Conference | Aug. 10-11 | Hybrid Event | New York, NY

Advertising Regulation Conference | Oct. 15-16 | Hybrid Event | Washington, DC

FINRA Small Firm Conference | Oct. 27-28 | In-Person Event | Chicago, IL

FINRA Certified Regulatory and Compliance Professional (CRCP)® Program Week II | Nov. 15-20 | In-Person Event | Washington, DC

Crypto and Blockchain Education Program Foundational E-Learning Courses | Self-Paced

Resources

Member Firm Hub – The latest guidance, resources, educational opportunities and more.

FINRA Forward – An overview of our work in action for becoming more effective and efficient at pursuing our mission is available on FINRA.org. The webpages include information and videos about our efforts to modernize our rules, empower member firm compliance, and combat cyber and fraud threats.

Quarterly Regulatory Policy Agenda – An overview of our current priorities for significant regulatory policy initiatives.

Comment ProcessOn-demand webinar on how to provide comments on FINRA Forward proposals, as well as the impact of comment letters and how they are used. 

Involvement and Election Process – How to engage with FINRA to help carry out our mission of protecting investors and safeguarding market integrity. Members can contribute their unique perspectives and skillsets with rotating terms on FINRA committees and other opportunities. Submit an indication of interest to be considered to join a FINRA advisory committee or speak at a FINRA event by clicking here.

Membership Application Program (MAP) Tools – Guidance and other resources to help current members prepare for their continuing membership application (CMA) and new applicants prepare for a new member application (NMA).

FINRA Unscripted – A monthly podcast that discusses a range of topics important to the securities industry.

Investor Insights – Feature articles on timely topics for investors, which firms are welcome to share with customers.

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FINRA is a not-for-profit organization dedicated to investor protection and market integrity. FINRA regulates one critical part of the securities industry—member brokerage firms doing business with the public in the U.S. FINRA, overseen by the SEC, writes rules, examines for and enforces compliance with FINRA rules and federal securities laws, registers broker-dealer personnel and offers them education and training, and informs the investing public. In addition, FINRA provides surveillance and other regulatory services for equities and options markets, as well as trade reporting and other industry utilities. FINRA also administers a dispute resolution forum for investors and brokerage firms and their registered employees. For more information, visit www.finra.org.
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