FINRA Releases 24 Enforcement Program Reform Recommendations
Broker-dealer member firms and their counsel must monitor these FINRA reform recommendations, as full implementation would fundamentally reshape how firms respond to enforcement inquiries, challenge information requests, and negotiate resolution terms.
On June 30, 2026, FINRA published a report from independent outside experts commissioned as part of its FINRA Forward initiative, outlining 24 recommendations to overhaul its enforcement program. Core proposed changes include adopting statute of limitations for most violations (tied to federal securities law timelines where applicable, or a general 5-year period for other violations), a formal process for firms to challenge overbroad Rule 8210 information requests before a neutral decision-maker, revised Wells notice due process rules including 30-day minimum response windows and immediate access to testimony transcripts, and updated cooperation credit guidance that eliminates the current 'extraordinary' standard for credit. While the recommendations do not immediately alter binding FINRA rules, firms with active enforcement matters can cite the report’s principles now to push back on unreasonable information requests and negotiate more favorable resolution terms, and should track implementation progress to invoke the proposed changes as they are adopted.