A Conversation With FINRA Chair Scott Curtis

At the 2025 FINRA Annual Conference on May 14, FINRA Chair Scott Curtis discusses topics of interest to FINRA member firms and other stakeholders, in conversation with President and CEO Robert Cook.

Resources mentioned in this episode:

Blog Post: Fee Rebate for FINRA Member Firms

Blog Post: FINRA Forward Initiatives to Support Members, Markets and the Investors They Serve 

Request for Comment: Outside Activities Rule—2025-05

Rule Proposal: Gifts Rule—2025-003

FULL TRANSCRIPT

0:01
Ray Pellecchia: In his first public remarks as the new Chair of FINRA, Scott Curtis, Chief Operating Officer of Raymond James Financial, talks about his career in finance, and his pathway to serving on FINRA’s advisory committees and then the Board of Governors. He discusses how FINRA member firms have a voice in the organization’s governance, including the board’s approach to important issues such as outside business activities, as well as the fee rebate to member firms, and the FINRA Forward initiative. He also discusses the importance of working to level the regulatory playing field between broker-dealers and registered investment advisors.   

0:49
Ray Pellecchia: Welcome to FINRA Unscripted. I’m your host, Ray Pellecchia. In this episode, we’re getting a view from the very top. It’s FINRA’s new Chair, Scott Curtis, in conversation with our President and CEO, Robert Cook. This discussion took place at FINRA’s Annual Conference on May 14, 2025. And it’s introduced by Marcia Asquith, FINRA’s Executive Vice President in charge of Board and External Affairs. Let’s listen in. 

1:18
Marcia Asquith: Good morning. I'm Marcia Asquith, the Head of Board and External Affairs here at FINRA. And I want to welcome you and say good morning. I hope you've taken advantage of the opportunities to network with your peers and to get to know FINRA staff who've been at the event this year. I also hope especially that you've had a chance to say hello to our CEO, Robert Cook. Robert will be hosting a conversation this morning with our new Board Chair, Scott Curtis.

1:48
Marcia Asquith: Scott will play a key role in guiding FINRA in the future years. Scott became Chair of the Board recently after having joined our board as a large firm governor in 2023. Yesterday when Robert introduced Chairman Hill and mentioned that he had been on an NASD committee and said look where that will get you. We could say the same about Scott.

2:10
Marcia Asquith: Before joining the board and becoming active that way, he had also served on our membership committee and is well known to our team. Scott has had a long and distinguished career at Raymond James. He was named Chief Operating Officer last year. His elevation to this role came after more than two decades serving in various senior leadership positions at the firm, including six years as president of the Private Client Group, the firm's domestic wealth management business.

2:40
Marcia Asquith: So it's fair to say that Scott is steeped in the technological, product and market trends that are shaping the brokerage business today. And of course, he's intimately familiar with the needs, interests and perspectives of you and your firms as you navigate these changes and an evolving regulatory landscape. A thought leader in the industry, Scott is a prime example of how the unique structure of the FINRA Board, with its balance of industry and public governors, gives voice to our member firms. 

3:12
Marcia Asquith: We at FINRA are enormously grateful to have the benefit of his deep industry experience and knowledge. With that, please welcome Robert Cook and Scott Curtis.

3:23
Robert Cook: Good morning, everyone. Scott, thank you so much for doing this. 

3:29
Scott Curtis: My pleasure.

3:30
Robert Cook: It's really a delight to have this first opportunity in your new role as chair of the FINRA board to introduce you to our audience here. Marcia gave a little bit of a recap of the top level of your career, but maybe just so people can get to know you a little bit better, if you could share maybe any highlights or challenges or what you found to have something interesting from your career that for interesting to you that you think would kind of give people a better sense of, of who you are and your background.

3:56
Scott Curtis: Sure. Yeah. And I'm delighted to be here with everybody and thank you again for the opportunity. I don't want to consume all of our time that we have today to give everybody a, a history of my career, but I joined Raymond James 22 1/2 years ago. Prior to that I was with a subsidiary company at GE—GE Capital—and prior to that I was at Morgan Stanley, in institutional fixed income in New York.

4:20
Scott Curtis: And safe to say, over my career in the financial services industry, which is the only business I've been in, I've served in a variety of roles from running leading operations for a medium sized life insurance company that GE Capital had acquired. I was asked to take on our e-business leadership when the Internet was really just kind of developing. I've been responsible for products and product management and I've been president of a broker-dealer along the way.

4:50
Scott Curtis: So the last 22 years at Raymond James, I've also had a variety of responsibilities and moved into the role that we call chief operating officer, which for many in the audience, you probably feel like that means, well, I must be responsible for operations and technology, and I'm not responsible for either. It's actually, I'm now responsible for our investment management, our advisory solutions, still our marketing, corporate meeting planning, our real estate globally and our facilities. And I spearhead a number of important firm-wide initiatives domestically as well as globally.

5:24
Scott Curtis: So domestically, just so people who are maybe less familiar with Raymond James, we have just a little under 8,000 advisors and that's a combination of independent advisors, advisors who operate out of credit unions and banks as well as traditional employee advisors. And then we also have an RIA custody business. So it's a diversified mix of businesses and we also have investment banking, fixed income, institutional asset management. We own two banks.

5:54
Scott Curtis: So it really is a diversified financial services company that operates under a bank holding company structure went public in 1983. The firm was founded in 1962 by Bob James, Tom James’ father. Tom was our CEO for 40 years. Paul Reilly was then successor to Tom. He was CEO for 15 years and Paul Shoukry became CEO just last year.

6:18
Scott Curtis: And it's really been a privilege and a pleasure to be a part of the organization and the senior leadership team for as long as I have. And I've really enjoyed my time on the FINRA board, which is, which is still relatively new, but it's been, it's been a really rewarding, fulfilling experience. So I appreciate the opportunity.

6:34
Robert Cook: Well, that's a great table setter for your background and the background of the firm. And maybe, switching over to the FINRA board, how does your experience in the industry and in your current role, how does that inform your thinking as a, as a member of, of the FINRA board and as chair of the FINRA board?

6:52
Scott Curtis: When I think about our responsibilities in terms of market integrity and investor protection, which are really the two guiding lights, the North Stars for us as a board and as an organization of FINRA. 

7:09
Scott Curtis: I've experienced over my career a lot of different regulatory requirements. And some of those requirements make complete sense when you think about market integrity and investor protection. And we have an entire supervisory compliance, risk management, AML, cybersecurity, all  that infrastructure to make sure that we as a firm are focused on investor protection, probably similar to a lot of the folks in the audience.

7:34
Scott Curtis: So I think, and I know you commented on this yesterday, on the board, one of the things that we're really thinking about is how do we preserve both of those, but help organizations operate much more efficiently. And also, how do we help organizations operate more effectively with the resources that they have and hopefully help them with perhaps not as many resources or pivoting those resources toward what might be higher risk areas within their organizations and what they're either their advisors are engaged in, or what their institutional businesses are engaged in. 

8:13
Scott Curtis: I think that is helping shape a lot of the conversations that we're having at the board level. And certainly, I'm delighted to be a part of that and help shape that. And one of the things that I've really been impressed with and pleased about is the willingness and openness of the FINRA senior leadership team—starting with you, Robert—how open people are to engaging in those conversations and talking about how can we reduce the unnecessary burdens for the member firms and how can we help them get become more efficient.

8:49
Scott Curtis: And if there are certain tasks that those firms are responsible for to comply with the rules, are there ways that maybe we can adjust the rules or at least get feedback and input from those firms to help us be better at what we do and do it in a way that doesn't require hiring another army of a few hundred people to oversee the activities, whether they're institutional activities or their advisory activities. And that's a long-winded response.

9:15
Robert Cook: No, no, that conversation we've had with the board, including over the last several meetings, really was the foundation for this FINRA Forward initiative. And it was just so helpful to have folks like yourself and other people from the industry and our public governors help kind of brainstorm the next mountain we want to take. So we appreciate that.

9:37
Robert Cook: Maybe turning to the board itself, just for a second, it can sometimes be a bit of a mystery to people who haven't been in the room. How does it work? What are the conversations like? Could you give a little bit of insight into the board and how it operates from your perspective, maybe was there anything that surprised you when you first joined the board or that did not surprise you?

9:56
Scott Curtis: Sure. And as one who was not on the board, it was a mystery to me as well. And I'm happy to say that the board is made up of a diverse group of people and different backgrounds, different experiences, different expertise. But it's a group that is collectively committed to continuing the mission of FINRA. And we don't necessarily always agree on items.

10:26
Scott Curtis: What probably surprised me is how FINRA operates without any political motivation in one direction or another. That was a very pleasant surprise, something I didn't really know what to expect. So that's been a real pleasant surprise, that FINRA is not a political organization at all.

10:49
Scott Curtis: The other thing that surprised me a little bit, as I said, Raymond James is a public company and our board, our board meetings, the structure is the first day we have committee meetings, a variety of committee meetings, board dinner that evening typically with the executive leadership team of the firm. And then the following day is the board meeting where we get report outs for the various committees. And so at my first FINRA board meeting, I was very familiar with that structure and pleased that FINRA follows the same structure which may surprise people. So board members are asked what committees they might be interested in participating in, or if we have a need, we might have a board member who's new to the board get assigned to a specific committee.

11:36
Scott Curtis: But those committees are focused on specific aspects of FINRA and FINRA's operations, whether it's talent, whether it's finance, whether it's operations, whether it's technology, whether it's regulatory policy, regulatory oversight. So it's a variety, but each committee is focused on that specific area. 

11:54
Scott Curtis:
And with terms for FINRA governors limited to three years for public and for industry governors, there's a need to be sourcing potential new governors regularly. And so the nominating and governance committee, there's a fair amount of time spent on succession, potential successors for governors.

12:15
Robert Cook: It's three years and then another three years—two terms. But there is a lot of turnover.

12:13
Scott Curtis: That's right. There's regular turnover. And, and as we saw with Eric [Noll, former FINRA Chair], occasionally there might be an opportunity that gets in the way of being able to continue to serve on the board.  So sometimes it's unexpected. But from my perspective, it's very well run. And I think the interactions with FINRA's senior leadership are very constructive and I'm proud to be a part of it. 

12:40
Robert Cook: What I neglected to mention, there are different seats on the board and you're actually in a large firm seat, and it's an elected seat. So you had to go through an election to get onto the board in this seat.

12:53
Scott Curtis: I was fortunate, as you probably recall, that I was unopposed. So it was the easiest election I've ever had. But that's not always the case.

13:04
Robert Cook: No, it's not always the case, and you also need to get a quorum, right. So there's still a need for the large firms—enough of them—to vote for you.

13:11
Scott Curtis: That's right.

13:13
Robert Cook: There are different industry seats on the on the board. Some are elected; most are elected, a couple are appointed.

13:16
Scott Curtis: And that diversity is helpful. Small firms, medium sized firms, firms that have a seat on the floor, wealth management focused firms, asset management firms, firms that are primarily custody, direct to consumer versus advisor. So I think it's important that we have that blend and it's not represented exclusively by folks who are primarily wealth management focused because FINRA’s spectrum is much broader than that.

13:43
Robert Cook: So FINRA is a unique organization as an SRO, a membership organization. And obviously there are other ways you could think of designing a regulatory system, but 85 years ago they thought it'd be a good way to design ours this way. And it's proven remarkably successful. But I think it's always worth our reflecting on, what does it mean to be an SRO? So you've been in a leader in the industry at a member firm for a long time, now you're helping to lead FINRA. What's your perspective on the value that an SRO can provide or should provide?

14:15
Scott Curtis: As I've thought about this question, what really strikes me is the level of engagement between member firms and the FINRA leaders. And so there's a closeness in understanding the various business models that with other—because we're subject to other regulatory oversight—with some of the other regulatory approaches, that same closeness doesn't exist.

14:42
Scott Curtis: One of the things that I'll point to, because this was really my introduction to FINRA, is the committee structure and the variety of committees that help ultimately inform the board as well as inform FINRA leaders who are responsible for leading those various committees. And my first exposure, which goes back now probably about 15 years was the Independent and Insurance Advisory Committee. I think it was called something like that. 

15:15
Scott Curtis: And back then there were no term limits. So I was on that committee for a while until that merged in with the Membership Committee, which at the time was led by Chip Jones [former Senior VP, Member Relations and Education at FINRA]. So I was on the Membership Committee, and then term limits were established, which made sense to me; let's allow a rotation. And the folks who are on those committees, those of you who've served on a committee, thank you for serving on the committees. And for those of you who have not yet served on a committee, I encourage you to at least explore it because it's rewarding, and your input does directly inform FINRA and does directly inform the board.

15:50
Scott Curtis: So I had a great experience on the membership committee and then it turned out, I happened to be on the FSI [Financial Services Institute] board at the time and a large firm seat opened up and I decided to pursue that, and here we are today. So I think that level of engagement and closeness with the firms and the organizations that are overseen by FINRA is really what differentiates FINRA from some of the other regulatory bodies.

16:20
Scott Curtis: We are, as a federal bank holding company, we're also overseen by the Fed. And our model, because we're not exclusively a bank, we own two banks, is different from most of the other organizations they oversee. And so we, we spend, appropriately, a fair amount of time educating the Fed examiners on our various businesses within the holding company.

16:42
Scott Curtis: And it's very interesting, but I think with FINRA, because of the complexity and the different flavors of firms that are overseen by FINRA, regulated by FINRA, it's really helpful to have that level of closeness so that there's a higher level perhaps of understanding of what is it that these firms are doing in terms of their business model and what are they trying to achieve. And what are the potential risks, and what are the various rules that apply.

17:06
Robert Cook: You mentioned the advisory committees, and thank you for the plug. We do have a lot of folks in the audience who've been on a committee and hopefully others will be interested in joining. So you served there, and now you're serving on the board level. Have you seen instances where you felt like things have changed because of input from advisory committees or, you know, took on a different path than they would have otherwise? In other words, did you feel like your input was meaningful on the advisory committees or even at the board when it comes to rules or the like?

17:40
Scott Curtis: I think back to my time on the Membership Committee, and that was also a somewhat diverse mix of representatives on the Membership Committee. And the DOL [Department of Labor] rule, I'm going to say round one, which is just before Trump was elected the first time, there was a lot of conversation about share classes and mutual fund share classes and not knowing what direction that we were going to go. 

18:05
Scott Curtis: There were some from FINRA less familiar perhaps with the structure of mutual fund share classes and the potential downside of a certain share class that was being promoted by one particular firm that shall remain nameless. And he thought that perhaps the rest of the industry would adopt that structure. And in that committee meeting, I can recall a couple of us explaining why it did not make sense to pursue that structure. And so I think that was helpful from an education standpoint.

18:36
Scott Curtis: And there were other instances where open dialogue helped shape and helped inform what was perhaps the recommendation that was ultimately going to go to the board. And so should FINRA support the direction that was being recommended or were there reasons to pause and kind of rethink? And so that was that was rewarding.

18:55
Scott Curtis: And I think about today on the board and conversations we've had, I know you mentioned this yesterday, regarding outside investments and outside business activities. We had some pretty lively discussions already on the board regarding what can we do and where are the areas that we can reduce the oversight burden where it's not really adding value and it's not necessarily consistent with market integrity, preserving market integrity and investor protection. And if someone who is an associate or a registered person with a firm, if they'd like to pursue volunteering for Habitat for Humanity or they want to lead the local Girl Scout or Boy Scout troop, as long as they're not controlling funds and acting in a capacity as an advisor, then why should we as a firm care about that? 
And certainly why should FINRA be concerned about that?

19:48
Scott Curtis: So I think we've made progress there and I'm looking forward to many others as we get input from member firms regarding areas where they're finding little value or questioning what's the value and why do we need to do this. 

20:00
Robert Cook: I think that's such a great example, because if you're just sitting in a room and thinking about what would be the right way to approach an issue like outside business activities, you might come up with a certain framework. But then to have that informed by, what do firms actually do and, and to hear, well, we actually want to have some guidance on this one, or, our policies say this already, so it's really, you're not adding anything, but here you would be adding. I mean, that level of nuance is incredibly valuable because you can say, well, we don't actually need to write a rule here, or actually the industry would find it helpful to have a level playing field on this issue.

20:39
Scott Curtis: Right. I look forward to revisiting the gift limit as well. Probably a lot of people in the audience do too. I know we took a run at that. We took a run at that many years ago and we had a lot of discussions in the Membership Committee about it. And the rules have to be approved by the SEC and at the time the SEC said that's not one of our priorities, we're not going to act on it. So it kind of got set aside.

21:00
Robert Cook: Your wish is our command.

21:02
Scott Curtis: There we go.

21:05
Robert Cook: It might not surprise you to see then something coming forward hopefully relatively soon. And Bob Colby's watching, he can elaborate on the Ask FINRA panel tomorrow.

21:14
Robert Cook: That's a great segue to, you know, we've been talking a lot about rule modernization and how do we make sure that our approach is consistent with the modern markets, modern firms, modern investors. And as we look out on the industry, are there developments that you're seeing that you think we ought to be focused on as an industry, and or, in terms of FINRA’s approach to those issues?

21:39
Scott Curtis: This one falls outside of FINRA's purview, but when I think about the what I'm going to call the imbalance between RIA [registered investment adviser], independent RIA oversight and the rules that are applicable to a broker-dealer or dual registrant because of the FINRA registration, it's curious to me and a little troubling to me that the playing field is not more level. Two items in particular that that I'll surface in our conversation this morning.

22:04
Scott Curtis: A number of these RIAs are—particularly the RIA aggregators—are becoming large and there still is not a capital requirement for those large RIAs provided they don't also have a broker-dealer. And I think everybody in the room knows, broker-dealers, we have net capital requirements. And so there are smaller firms, medium sized firms that are not self clearing, but they still have the capital requirements, they still apply.

22:31
Scott Curtis: And for these RIAs, many of which have grown to be larger than some of the smaller broker-dealer firms, it's a bit of a head scratcher to me why there isn't some level of capital requirement when they're effectively operating in in the same manner as perhaps a smaller broker-dealer and providing advice and recommendations ultimately to clients, to investors. That's one that's curious to me.

25:51
Scott Curtis: And then the other one we talked about, effective or reasonably designed oversight, our CEO happened to be, we have a custody business as I mentioned with one of our client firms who custodies with us, an RIA firm, and he just happened to ask when was the last time you were examined by the SEC? And they said, in 2016. So they'd not had an exam in over eight years. And to me, in the broker-dealer space, that would almost be unheard of that we would not examine one of our significant branches or advisors in in eight years.

23:33
Scott Curtis: So there should be some way of levelling the playing field a little bit more and making sure that if you are in the business of providing advice to end clients, to end investors, that there is a higher level of frequency. And I think leveraging technology, even though we know, based on what we've read anyway, that perhaps the SEC has fewer resources today than they had a few months ago. But there should be a way, leveraging technology, where those exams could be conducted without necessarily having to have a human being on site.

24:02
Robert Cook: Well, I think it's an important observation. I hear it from a lot of our member firms who feel—in the wealth management space, in particular—they're competing on an uneven playing field. And I think it's a very important perspective when we're thinking about our rules because we can ask, OK, is there a difference? And if we have a rule that doesn't exist on the RIA side or that doesn't exist at the same level, should we? And maybe we should, but we have to think about that, as the channels have merged, we can't do anything about the RIA side; that's up to the SEC. But we can ask, are we doing what we can within our domain on the broker-dealer side.

24:44
Scott Curtis: Right. And for an end investor, for a client, they don't know the difference. 

24:50
Robert Cook: Right. One final question for you. Shifting back to your role on the board, and for now,  Chair of the Finance Committee. We’ll probably have to relieve you of that now that you're Chair of the Board, but you were Chair of the Finance Committee. And you know, we previewed yesterday that looking at our performance in 2024, we think we're in a position to provide a rebate for the membership. But just to get your perspective; finances matter—it's our members’ monies—of the role of the Finance Committee and how it thinks about everything from fees to budget to rebates.

25:25
Scott Curtis: It's a really important function obviously within FINRA because it's a considerable amount of revenue that comes into the organization. By the way, for anybody who has not looked on FINRA’s website, there's a great level of transparency around sources of revenue, uses of revenue within the organization. We do pay close attention to that in the Finance Committee and similar to organizations that make projections about interest rates and trading levels etcetera, we have to do the same thing and we monitor that at minimum each quarter.

26:00
Scott Curtis: I know Todd [Diganci, FINRA’s Chief Financial Officer and Executive VP] and Jeff [Kalinowski, Senior VP, Enterprise and Financial Solutions] and the finance team do that a lot more frequently than the board does. But if we need to make adjustments, the good news is we have the flexibility to do that. And I think what you announced yesterday is a great reflection of that. We underestimated the revenue we now have, and we perhaps overestimated expenses and what those would look like this year. Revenue has come in better than expected. Expenses are about in line with what we expected.

26:22
Scott Curtis: And with that outcome, we can rebate back the fees that we've collected. We're not a for-profit organization. That's never been the mission. And so it makes sense to rebate those fees that we've collected back to the member firms. And I wasn't in the audience yesterday, but I assume you got an applause for that. I know I applauded when we were talking about it.

26:40
Robert Cook: Well, I think people might wait and see if the check’s in the mail.

26:46
Scott Curtis: Wait for the payment. 

26:50
Robert Cook: Well, Scott, we're just so delighted to have you serving as our as our Chair, and appreciate your spending some time here with the members. And we look forward to getting you back here at future annual conferences. So, thank you. Please join me in thanking Scott for being with us. 

27:00
Scott Curtis: Thank you.

27:10
Ray Pellecchia: And that’s it for this episode of FINRA Unscripted. Listeners, if you don't already, please be sure to subscribe to FINRA Unscripted wherever you listen to podcasts. All of the resources mentioned in today's podcast will be included on the home page for the podcast episode. Today's episode was produced by me, Ray Pellecchia, and engineered by John Williams. Until next time.