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FINRA Forward Rule Modernization Continues

October 1, 2025

Features

  • FINRA Forward Rule Modernization Continues 
    Robert Colby, FINRA Executive Vice President and Chief Legal Officer, provided an update this week on rule modernization efforts under the FINRA Forward initiative. “FINRA wants to ensure that in today’s environment and tomorrow’s, our rules help protect investors and safeguard market integrity without imposing unnecessary burdens on firms,” he wrote in a blog Monday. 

    Colby described how FINRA has expanded the traditional rule review process, including issuing three broad public comment requests that generated more than 125 written comments. He also noted recent Board approvals to simplify outside activities requirements, raise the gift limit to $300 per person annually, and amend our rules to ease requirements on capital acquisition brokers (CABs) and promote capital formation without lessening investor protections. 
     
  • Last Days to Apply For SFAC, Regional Committee Vacancies 
    FINRA will hold elections this month to fill vacancies on our Small Firm Advisory Committee (SFAC) and regional committees. To be included on the ballot, eligible candidates must submit an SFAC candidate profile form or regional committee candidate profile form to FINRA’s Office of the Corporate Secretary by Oct. 6 via email
     
  • FINRA’s Crypto and Blockchain Program Goes Live 
    Foundational courses on crypto and blockchain are now available to member firms on FINRA’s e-learning platform. These courses establish a solid understanding of crypto assets, enabling participants to recognize key concepts and terminology relevant to the evolving crypto landscape. They are part of our ongoing commitment to educate the industry, empower firm compliance, and ensure our programs and activities are in line with the opportunities and risks in today's capital markets. More information on these offerings and future crypto and blockchain trainings is available here on FINRA.org. 
     
  • FINRA Enhances Reporting Platform to Enable Vendor-Submitted Reports 
    Enhancements are underway to our reporting platform that will enable authorized third-party vendors to fulfill firms’ reporting obligations through a secure framework. This capability addresses industry feedback requesting more flexible reporting options and streamlined workflows.  

    Starting today, member firms will be able to authorize third-party vendors to submit SEC Rule 606(a) Reports on their behalf, pursuant to FINRA Rule 6151. Vendors acting on behalf of members will be able to use FINRA Gateway to upload the reports manually or via machine-to-machine interface. Step-by-step instructions are available here, or you may contact us with questions at [email protected]
     
  • FINRA Reinforces Obligation to Comply with Information Requests 
    FINRA reminded member firms and associated persons that they must comply with Rule 8210, which authorizes FINRA staff and adjudicators to request information for purposes of an investigation, complaint, examination, or proceeding. The Sept. 25 Notice reminds member firms and associated persons that the requirements of Rule 8210 apply regardless of where they are located, does not provide an exception for potentially conflicting foreign laws, and that non-compliance can result in sanctions including firm expulsion or individual bar from the industry. 
     
  • Pretest Questions to be Reduced for Key Securities Exams 
    Effective Oct. 27, FINRA will reduce the number of unscored, or pretest, questions delivered to candidates on the Securities Industry Essentials (SIE), Series 7—General Securities Representative, and Series 79—Investment Banking Representative exams. Candidates who take these exams will receive five unscored questions instead of 10. The duration of these exams will not change. For any questions, please contact FINRA Candidate Services at [email protected]
     
  • Cyber Alert: Critical Cisco Vulnerabilities 
    FINRA member firms and their vendors should be aware that Cisco recently identified multiple vulnerabilities—several of them listed as critical—that could allow threat actors to compromise a firm’s systems. For more information, read FINRA’s Cybersecurity Alert here
     
  • ICYMI: FINRA Board Holds September Meeting 
    At their Sept. 17-18 meeting in New York, the FINRA Board of Governors received a progress update on FINRA Forward and approved related amendments that will replace the day trading and pattern day trading rules, including the minimum equity of $25,000 for pattern day traders, with an intraday margin rule that applies the existing maintenance margin rules to intraday exposure. These and other updates are detailed in a letter FINRA President and CEO Robert Cook sent to member firms last week. 
     
  • ICYMI: Regulatory Element Training Topics Now Available 
    Members can preview the 2026 Regulatory Element training topics to help prepare for next year’s continuing education requirements. FINRA Rule 1240 requires all registered reps to complete the Regulatory Element annually by Dec. 31 for each registration they hold. You can visit our website and select the appropriate registrations to view the learning plan for those registrations.
Regulatory Information, Upcoming Deadlines, Effective Dates
New
  • Vendor-Submitted Reports: Starting Oct. 1, member firms will be able to authorize third-party vendors to submit SEC Rule 606(a) Reports on their behalf. See feature above for details. 
     
  • Pretest Questions: Effective Oct. 27, FINRA will reduce the number of unscored questions on key securities exams. See feature above for details.
Reminders
  • Committee Election Notices: Members who are interested in joining the SFAC or regional committees must submit an SFAC candidate profile form or regional committees candidate profile form to FINRA’s Office of the Corporate Secretary by Oct. 6 via email
     
  • SEC Requests for Comment 
     
    • CAB Rules: Comments on FINRA’s partial amendment are due to the SEC by Oct. 21. Comments on SEC’s order instituting proceedings are due to the SEC by Oct. 7 and rebuttal comments due by Oct. 21.
    • Gifts Rule: Comments are due to the SEC by Oct. 8 and rebuttal comments are due by Oct. 22
       
  • New Portal for Office of Hearing Officers Matters: FINRA’s secure electronic portal to replace email as the primary method for the filing and service of documents in Office of Hearing Officers proceedings will go live on Oct. 7. As described in Reg. Notice 25-10, this will modernize service and filing processes in a way that will protect investors and the public interest by promoting efficiency while preserving fair process. 
     
  • LULD Plan Operating Committee Seeks Advisory Committee Reps: The Limit Up/Limit Down (LULD) Plan Operating Committee is accepting applications for advisory committee representatives, with submissions due Oct. 10
     
  • FinCEN Extends Deadline for Money Laundering Order: FinCEN revised its June 25 orders prohibiting covered financial institutions from transmitting funds from three Mexico-based entities—CIBanco S.A., Intercam Banco S.A., and Vector Casa de Bolsa, S.A. de C.V. Firms now have until Oct. 20 to implement the orders. 
     
  • FINRA Forward Initiative to Streamline Delivery of Required Information: 
    FINRA will adopt new system enhancements on Nov. 3 to enable member firms to electronically deliver required information relating to Form U4, Form U5, and predispute arbitration through our Financial Professional Gateway (FinPro GatewayTM). As a result, member firms will have the option of satisfying those requirements through FINRA systems in a more timely and efficient manner, and at no additional cost. These enhancements are part of FINRA Forward, a series of initiatives to support members, markets, and investors.  
     
  • Timeline for Registration Renewals: The timeline for member firms to renew their registrations is now available. Preliminary statements will be posted to E-Bill on Nov. 10, and renewal reports can be accessed through CRD/IARD for reconciliation purposes. See the Firm Renewal Report Guide for details. 
     
  • 2026 Regulatory Element: FINRA Rule 1240 requires registered persons to complete the Regulatory Element annually by Dec. 31 for each registration that they hold.  
     
  • The Modern Workplace: Regulatory Notice 25-07 requested comment on further evolving FINRA’s rules, guidance, and processes to reflect modern business practices and markets; support innovation; promote efficiency; and eliminate unnecessary regulatory burdens. The comment period has closed, but we still welcome feedback. 
     
  • Rule Modernization: Regulatory Notice 25-04 requested comment in connection with a broad review of FINRA’s regulatory requirements applicable to member firms and associated persons. The comment period has closed, but we still welcome feedback. 
     
  • Capital Formation: Regulatory Notice 25-06 requested comment on modernizing FINRA rules, guidance, and processes to further facilitate capital formation and reduce unnecessary regulatory costs and burdens impacting the capital raising process. The comment period has closed, but we still welcome feedback.
Disciplinary Actions
FINRA publishes disciplinary actions to remind members of specific conduct that violates FINRA rules and may result in disciplinary action. The September 2025 Monthly Disciplinary Actions are available here.
Education and Compliance Programs
 
Cyber Tabletop Exercise | Oct. 8 | Dallas, TX | In-Person Event  
 
Senior Investor Financial Exploitation Case Study Workshop | Oct. 8 | Dallas, TX | In-Person Event  
 
Small Firm Conference | Oct. 9-10 | Dallas, TX | Hybrid Event
 
 
Registration Systems Foundation | Oct. 28-29 | Virtual Event | Sold Out
 
Joint Compliance Outreach Program for Municipal Advisors, Dealers, and Other Market Professionals | Hosted by FINRA, the SEC and the MSRB | Nov. 18-19 | Virtual Event
Resources
Member Firm Hub – Latest guidance, resources, educational opportunities and more. 
 
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 – Monthly podcast on a range of topics important to FINRA members and other stakeholders.
 
Investor Insights – Feature articles on timely topics for investors, which firms are welcome to share with customers. 
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About FINRA
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.
Regulatory Contacts
FINRA By-Laws require member firms to maintain an email account on behalf of their executive representatives, to facilitate firm notification of important information. In light of this, requests from executive representatives to be removed from this email list cannot be honored.
 
Firms wishing to change the name or email address of their executive representative or designated assistant should use the FINRA Contact System: http://www.finra.org/FCS.
 
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