PODCAST
Inside FINRA Forward: A Conversation with FINRA Board Chair Scott Curtis
On this episode, tune in to a conversation from FINRA’s 2026 Annual Conference, where FINRA Board Chair Scott Curtis and FINRA President and CEO Robert Cook discussed the partnership between board governance and executive leadership, and the strategic priorities shaping FINRA's direction.
Resources mentioned in this episode:
Ep. 185: How FINRA Is Streamlining Data Requests
Ep. 187: How FINRA Is Enhancing Member Firm Examinations
FINRA Forward: A Year of Progress
FINRA Quarterly Regulatory Policy Agenda
Blog Post: FINRA Forward’s Rule Modernization—An Update
Blog Post: Vendors, Intelligence Sharing and FINRA’s Mission
Blog Post: FINRA Forward Initiatives to Support Members, Markets and the Investors They Serve
Blog Post: A Progress Update on Rule Modernization
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FULL TRANSCRIPT
00:00 – 01:25
Margherita Beale: The financial services industry is evolving rapidly. FINRA's leadership is working to adapt to these changes while maintaining our core commitments to investor protection and market integrity. How does our board approach these challenges? What's driving FINRA's strategic priorities? That's what FINRA Board Chair Scott Curtis and [FINRA] President and CEO Robert Cook explored in a recent conversation at FINRA's 2026 annual conference.
Welcome to FINRA Unscripted. I'm your host, Margherita Beale. Today we are bringing you an in-depth conversation between Scott Curtis, who chairs FINRA's Board of Governors, and Robert Cook, FINRA's President and CEO, moderated by Marcia Asquith, FINRA Executive Vice President of Board and External Relations. They discussed the partnership between board governance and executive leadership, explored the strategic priorities shaping FINRA's direction, delved into the unique characteristics of the self-regulatory model, and tackle timely industry issues, from rule modernization and other FINRA Forward initiatives to the emerging challenges of the broker-dealer investment advisor regulatory landscape. All of this and more on this episode of FINRA Unscripted. And now, here is that conversation between Scott and Robert.
01:25 – 04:05
Marcia Asquith: I am Marcia Asquith. I'm the Corporate Secretary and work with the Board of Governors and I'm also the Head of External relations. We are delighted that you're here to talk with peers in the industry and to learn more about what's going on at FINRA. And today I want to introduce you to two of the top leaders at FINRA. They help us make everything possible, all the work we do. Scott Curtis is the chairman of FINRA's Board of Governors. And you know Robert Cook, FINRA's president and CEO.
Scott has served as our board chair since February 2025, and we are fortunate to have the benefit of his long experience in the industry. Scott is chief operating officer of Raymond James, a role he assumed in 2024 after serving for more than two decades in various senior leadership roles at the firm, including years as president of the private client group. During this long and distinguished career, Scott has helped to see Raymond James through many economic ups and downs in the wealth management business and has had a front row seat to its evolution. He is steeped in market dynamics, product trends, and technological forces shaping the industry today. He's intimately familiar with the challenges and opportunities facing FINRA member firms. As an influential voice in the industry, Scott is a prime example of the strength of FINRA's governance model, where industry and public governors work together to ensure member firms are heard and represented. Scott, welcome and thank you for being here.
I'm going to turn to Robert for a minute. I know that you all see Robert throughout the conference, but I don't know that you know that in running the day-to-day management of FINRA and setting our strategic direction, this responsibility of his is hugely informed by his background of combined private sector and regulatory experience. He served as head of the Division of Trading and Markets at the SEC for three years before coming to FINRA. And before that, he was a partner at Cleary Gottlieb where he represented folks in this space. So, he comes with a background steeped in the issues facing the industry.
As Scott and Robert carry out their respective roles, I think it's just important for you all to know that they are in constant conversation. And so, with that, I'll turn to our first question. And Scott, I talked a little bit about it in the intro, but you chair the board and Robert, you lead the day-to-day management of the organization. And I think explaining how that partnership works in practice, what does that really mean, and how do you do that?
04:05 – 05:45
Scott Curtis: Thank you, Marcia. It's great to be here with everybody. Great to be back at what is, believe it or not, my second annual conference. We were here last year and that was my first one. So, it's fun to be back. And I appreciated that introduction. Robert and I had a relationship previously through my experience as a governor on the board. But now he and I speak at least weekly on a variety of matters that are relevant to FINRA, relevant to all of you and our industry. Our focus really is how do we make FINRA better for the industry, for all of you? How do we remove, how do we modernize, the set of rules that apply to all of us in the industry? And at the same time, having market integrity and investor protection remain our guiding principles and really our foundation for everything that we do. So there had been many conversations around how do we move forward, what are the priorities, and I know, Marcia, you're going to get to questions regarding the Board's involvement and how we operate, but I've really enjoyed the experience thus far as Board Chair. I've learned a lot, and Robert and I have certainly become a lot closer through those conversations. Believe it or not, if you didn't know this, we grew up in the same community up in a little small town, New Hampshire and Vermont, and went to the same high school, although not at the same time. He clearly is considerably younger than I am. But with that background, we had a natural affinity for getting to know each other at another level beyond just...
5:45 – 05:47
Robert Cook: We did not know that until after [you became]…
05:47 – 05:48
Scott Curtis: We did not know that.
05:47 – 05:48
Robert Cook: … Board Chair.
05:48 – 06:20
Scott Curtis: That’s right. Yeah, so anyway, the role of the governor is helping set the tone at the Board meetings and helping prioritize and making sure that the governors who participate in the meetings, that everyone has an opportunity to provide input and feedback on the matters that we're discussing. And we, I'm proud to say, have a wonderful Board, a wonderful group of governors, and everyone is focused on the same thing. How do we continue to evolve the organization, move it forward, modernize the rule set that apply to all of us?
06:20 – 07:32
Robert Cook: Yeah, I would just echo everything Scott said. I mean, it is a governing board. It's not an advisory board. Think of it like a corporate organization where the board has oversight responsibility for overall strategy, budget, things like that, but then it's management's job to execute. But we're so fortunate to have an incredibly talented Board that one of the challenges I have in the management role is not to bring them down into the weeds too much because why wouldn't I want to talk to some of these folks about the issues we're facing? I'm incredibly grateful for the opportunity to avail myself of Scott's deep expertise in the industry, but also as a senior leader of a large organization. It's just great to have someone to talk through day-to-day issues with, and Scott's that person for me now, and I really appreciate that. It helps me be better at my job. But as I said, it's not an advisory board. The Board really does weigh in on, in a substantive way, the big issues. And when it comes to things like rules, the Board has to approve each and every one of those and has the rule text in front of them when they do so. They’re very much involved in that aspect of the organization.
07:32 – 07:40
Marcia Asquith: So, Scott, you're a year in to your tenure as chairman. What are your priorities for the year ahead and what is shaping those priorities?
07:40 – 09:50
Scott Curtis: You may recall this, Marcia, when we were at the 85th year of FINRA celebration, someone who was there asked me, “So Scott, as Board Chair, what would you like your legacy to be when your period as Board Chair concludes?” And I had not been asked that question before and had not really thought about it before, but I responded, rule modernization and executing on FINRA Forward. That's really what I would like my legacy to be. We have, we believe, a somewhat limited time, it's unknown, but a somewhat limited time to execute on the rule modernization that we're trying to move forward on. So there is some urgency and I think that's felt by everyone on the Board. You don't know how long, when administration changes, you don't know what the environment's going to be like. So today, with Paul Atkins as SEC Chair, we feel like we're in a really good position to actually affect positive change for the industry. So that's our focus and that hopefully will be the legacy, when my period as Board Chair concludes, perhaps in three or so years, depending on the election. One of the responsibilities of the board, as well as senior leadership of FINRA, is financial management, financial oversight. And when the markets were in a different place, interest rates were in a different place, FINRA had to get approved fee changes, fee increases, not anticipating what was going to happen with transaction activity, which generates additional revenue. And we found ourselves in a place last year where we had excess. We are a nonprofit organization and it made sense to rebate back to member firms $50 million. And more recently, this year, we rebated back to firms $100 million. So, we've had pretty lively conversations at the Board about what are our assumptions going forward? What do we think will happen with markets, transaction activity? And the fee increases that were approved, do we still expect that those will be necessary or do we need to file a change with the SEC to actually pull those back or at least delay them or defer them? So I think fiscal responsibility is also a really important part of what the Board does.
09:50 – 10:11
Marcia Asquith: So talk a little bit, both of you, about how the board approaches the preservation and the analysis of the self-regulatory model. How do we think about it? I mean, the board talks about that a lot, but you want to share the characteristics, or what is it that the board is focused on when we talk about the SRO, as Chairman Atkins said yesterday?
10:11 – 10:12
Scott Curtis: Want to kick that one off?
10:12 – 12:23
Robert Cook: Sure, well it starts in the boardroom itself. You have folks like Scott and other elected governors like Scott, small, medium, and large, and some appointed governors from the industry. They're at the table. They're helping to bring the industry perspective right into the boardroom in terms of both decisions like the budget or rules that we need to adopt, as well as oversight and how the programs are being run on a regular basis. And even with respect to matters that go through our judicatory process, they have the ability to review those and weigh in on them. And of course, we have a terrific group of public governors who are part of that discussion as well. It's a very collaborative discussion, I think, and sometimes there's perceptions about, from [the] outside, what it must be like inside. And we've talked about this at this conference in years past. It's not like you got one side or the other. You [have] a lot of thoughtful people in the room who typically reach all decisions by consensus, or most decisions. And so, it's a very collaborative process, but you have the industry there, and weighing in. I think that's very unique for a regulatory organization. And of course, then layers below you have all of our advisory committees. Many of you have been on those or are on those. We appreciate the time that's put into that, all the rules that come to us or go through the advisory committees. That feedback gets reported up to the Board. So when the Board's making a decision about whether to proceed, they can hear what did the advisory committees think. You were actually on an advisory committee before you joined the board, which is great. We've got our regional committees. We've got various working groups of industry. So there's all that input that's given to us live. And of course, then we have all the written input we get in the comment letters. The Board really takes all of that very seriously in deciding all the key things that need to be addressed at the board level. So, I think there's multiple channels of opportunity for industry input and then ultimate, decision making has a very significant piece of it through the industry governors on the Board.
12:23 – 13:51
Scott Curtis: Yeah, I would just add to that, Robert, you touched on it a little bit, the importance of diversity of perspectives. So, we have represented on the Board, we have the direct consumer business model, we have capital markets perspective, we have large firm, we have medium firm, we have smaller firm. So, for those of you in the audience, we have a wide variety of business models in the audience. And on the Board, we try to make sure that we have those perspectives represented as well on the Board so that we don't have simply wealth management-focused firms represented on the board. We want to have a diversity. That's really helpful as we go through a variety of topics because not every topic, not every rule that we're considering is applicable to each business model that's in the room. So, we want to make sure we have that knowledgeable perspective in the room to advise the rest of us on the board who are thinking about it. So it's critical to have that and as Robert said, the feedback from industry members is also critical as we contemplate what changes might be made. But self-regulatory organization is somewhat unique in that it's this group that in fact ultimately is responsible for how our businesses operate and the rules that apply to our businesses. And then we clearly have FINRA and the SEC making sure that we're following the rules that we supported when we put them in place.
13:51 – 14:09
Marcia Asquith: So, we're gonna turn to FINRA Forward. Robert, it was about a year ago that we launched FINRA Forward and you kicked it off with a blog and we have been talking a lot in the Board about FINRA Forward, but [do] you wanna go back a little bit and talk about what the rationale was at the time for launching it and how we approached that?
14:09 – 19:14
Robert Cook: Sure, and I think the why isn't the what because I think when you go through what we're doing with FINRA Forward, I hope it's self-evident why we would be doing these things. So when we launched it, we really focused initially on three areas. One was rule modernization that Scott already alluded to. And I think we've covered a lot there. I would again pitch to you the one-year progress report on FINRA Forward. It really gives you a nice summary of what we've been doing and a little bit of an insight into what's in the pipeline because of a lot of things that are underway that we hope to bring forward in the coming months. But on the rule modernization front, the idea was rules need to be updated regularly. The markets change, technology changes, the basic assumptions that upon which the rules are adopted become outdated. And so this is why it's so important to regularly review the rules. And so, our rules have been in need of it for a while and I picked some of the rules that we have been working on and that are at various stages of process.
The gifts limit is a small thing but it took a long time. I think, we talked about this last year, things like the pattern day trader rule, which was recently approved by the Commission, that hadn't been looked at in 20 years. There are things that are at the Commission now that we heard from the industry really needed updating. The outside business activity, personal securities transaction rule proposal that is awaiting, hopefully SEC updates to the communications rule, allowing firms to do more by way of projections and marketing, more consistent with what investment advisors can do.
Our board approved e-delivery. We haven't filed that with the Commission yet because we'd like to be able to move forward on that in parallel with the Commission. So, we're kind of waiting to see if we can move together. But our Board's already authorized us to file rules that would allow a default to e-delivery with people having the option to opt out. And there's a bunch more in the pipeline to come, including things like the supervision rules, making the remote inspection pilot permanent, the research rules.
There are big rules, there are small rules, they all matter to someone. I would recommend to you a new part of our website, which is our Regulatory Policy Agenda. It gives you really nice look, and we're going to update is it quarterly on what's been done recently, what's with the Commission, because once you file it with the commission, they have up to 240 days to act on it. So, what's sitting there? And then what's in the pipeline that we're working on? And we'll try to update that regularly based on where we are.
So the rule modernization hopefully is self-evident why we'd be doing that. That tends to get most of the attention. The other two things I'll mention briefly, empowering member firm compliance. The rationale for that is that our member firms are the front lines of protecting their investors. And our job is to help make that easier, provide tools, resources, et cetera. So things that we're doing there include, number one, reducing the data requests that we put out to firms. There's some great data in the progress report about how we reduce the volume of our data requests. Why does that matter? Because it takes time to respond to data requests and it takes money. And if we don't need to put out a data request, we don't need to do one as broadly. It actually frees up important resources for compliance offices.
Another area is pushing out more compliance tools and resources. Not just conferences like this, although this is important, but I hope you'll learn here, if you don't already know, the various tools and resources we try to provide, whether it's report cards or opportunities to engage with vendor staff around your advertising, whatever it is, the more we can help provide those resources, the more we're really enabling compliance and helping investors.
Looking at the exam program is another area. You'll see and hear at panels here about how we're looking at, how do we provide more notice about the exams that we're going to be doing, and how do we provide more insights into what we're looking at and expanding the exam cycle is one area that we've moved forward on, moving from a backstop of four years to backstop of six years for the lowest risk firms. Obviously, we're monitoring and engaged with firms throughout that process.
And then finally, fighting cybersecurity and fraud, which again, I think, doesn't need a lot of explanation. Obviously, it's a good thing, but what I think is a value add there is working together with the industry because it's an all hands on deck kind of challenge. And I think we see a lot of opportunities, which again, I hope you'll hear about at this conference for us to work together with the industry to better protect the industry and investors from that. So, I think a lot of that stuff is sort of common sense, but we saw a real opportunity to move forward quickly in this environment.
And we've added other initiatives here as we move forward, including our enforcement review, which we hope to bring to a conclusion by the end of June and put out a public report on that. Some of the other internal reorganizations and focus on our own internal training, use of AI. There's a lot going on. Again, the moment really, I think, speak to the needs and opportunities of the moment.
19:14 – 19:42
Scott Curtis: I would just add to that, Marcia, before you move on. And Robert alluded to it a little bit. But there also has been a real focus on how to operate more efficiently and embracing technology and technology tools so that FINRA can be a little more lean, perhaps, than it's been in the past and processes that have been largely manual, moving those to more automation. So that has kind of been a current that's run through everything now that's being done. And I think all of you should be pleased to hear that that is occurring as well.
19:42 – 20:10
Marcia Asquith: Robert, you mentioned the Enforcement review and we've gotten several questions harkening back to yesterday's comment by Chairman Atkins. The one applause line he got yesterday for those of you who missed it was that the SEC wasn't doing regulation by enforcement. How does FINRA think about its approach to enforcement, and is that same sort of mindset that the SEC has been saying in Chairman Atkins' comment, is that something that FINRA thinks about?
20:10 – 21:17
Robert Cook: Well, absolutely, and I think we'll talk more about this when we put out this enforcement review, but I think we would echo the notion that rules shouldn't be made up in the enforcement process. That should not be when people are learning what the rules of the road are. If the rules aren't clear, we should write new rules, but we should be enforcing standards that people had fair notice of in advance. But in many ways, as an SRO, our opportunity is really to work with firms on compliance up front and how can we make sure that things don't go off the rails in the first instance? And then how can we think about our whole toolkit that we have available to us besides enforcement, whether that's further guidance or providing better exam findings or other things we can do, provide more resources to firms. But we have a whole bunch of different tools available to us to address any particular situation and enforcement is only one of them. It's an important one and it's one that we're obviously take very seriously and what we will use when we need to, but we need to think about how we can work with the industry to avoid the need for enforcement as much as possible.
21:17 – 21:46
Marcia Asquith: So, one of the questions that we had had thought might be interesting for the audience and sure enough, got this, and Scott, I'll direct this to you. A question about the trend of movement into the IA and the dually registered BD-IA space. And the questions are now more pronounced about how investors are protected in that duality. What is your perspective on this trend and what issues do you think it creates for the brokerage industry and firms and members? I know that you have a lot of thoughts about this.
21:46 – 23:47
Scott Curtis: It’s probably one of my highest priorities. And certainly our Executive Chair, Paul Riley, our former CEO at Raymond James, it's one of his highest priorities. And when I get together and have conversations with senior leaders at other firms, broker dealers in particular that are either dually registered as RIAs or also have a separate RIA that their advisors roll up under, this regulatory arbitrage, as we refer to it, that exists today, we're trying to narrow that gap. And that doesn't mean that we as broker dealers should become more relaxed in terms of enforcing the rules. What we're trying to do is level the playing field a little bit. Robert mentioned the marketing rule and allowing forward projections. So specific to that rule, we're trying to align FINRA's rule with the SEC marketing rules so that there isn't a difference, that they are the same.
And one of the big questions that we have is around capital requirements. If you're an introducing broker dealer today, not a firm that custodies assets, but an introducing broker dealer today, when you think fundamentally about what you and what your organization does that maybe is different from what an RIA does, it's not that different. You're essentially acting as agent in placing orders on behalf of clients, whether it's under an advisory agreement or it's a commission-based brokerage account. And so, for a broken dealer, there are capital requirements. For an RIA, there are no capital requirements. Does that make sense and do investors understand that? And I think the answer to the second question is investors absolutely do not understand that. And from our perspective, that does not make everything okay, because we're fiduciaries as well. So how do we selectively prioritize and where are the areas of greatest difference that from our perspective just don't make sense? So that's what we're trying to focus on. And we'll see if we can make progress.
23:47 – 24:10
Marcia Asquith: So we need to wrap up, but I want you to leave the audience with your thoughts on how do you feel about the future of in an environment where there has been some criticism of FINRA from elected officials or the incoming administration. I know there's been some questions. We had a little bit of a different conversation about that from Paul Atkins yesterday, but what is your outlook for the future as we're facing this moment in time?
24:10 – 25:08
Scott Curtis (24:10.368)
It's a great question and I feel really good. I'm optimistic about the future of our business and the need for FINRA. I'm a firm believer in the self-regulatory organization model. So if you think about, what's the alternative? What if there wasn't FINRA? Then what? Who would be responsible for taking on all the responsibilities that FINRA manages today? And I don't think there's a good answer to that question. So, I think the focus is appropriate. How do we make FINRA more effective, how do we continue to make FINRA more efficient, and how do we modernize our rule set so that we can be the best self-regulatory organization that's out there and really the model for others in different parts of the marketplace. So, the need for FINRA, I don't think is going away. I think it will continue as strong as ever. And I have a high level of confidence that with the leadership team that we have and the Board that we have right now, we'll continue to make a real difference and continue to move this forward.
25:08 -
Robert Cook: Yeah, now I'm optimistic about the value that FINRA can bring and has brought over decades. I'm very appreciative of the support we have from our Board to make sure that we can lean into that. Our commitment is that we really want to be a forward-thinking regulator who is responding to the changing needs of the marketplace. We know that to do that though, effectively, we need the input and engagement of all of you. That's the only way that this model really works. And I think with it, we can do great things, but we want to make sure that we're continuing to reflect all the wisdom of the industry and the interest that the industry has in ultimately serving your investors and helping to promote great, strong, vibrant capital markets.
25:56 – 26:15
Marcia Asquith: Great, well thank you Scott, thank you Robert. Appreciate the time to talk about these issues and thank you to everyone for the questions and for being here and I hope you have a great day. We have a lot of great content and so we'll send you off into your day, so thank you.
26:15 – 26:40
Margherita Beale: And that's it for today's 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 homepage for the podcast episode. Today's episode was produced by me, Margherita Beale, and engineered by John Williams. Until next time.