FINRA has commenced a targeted review of member firm practices relating to public and private offerings undertaken by small-cap, exchange-listed issuers with business operations in foreign jurisdictions, including China (collectively, “small-cap offerings”).  The review focuses on (i) firms that have participated in multiple small-cap offerings as an underwriter, bookrunner, syndicate member, selling group member, or

FINRA’s President and Chief Executive Officer, Robert Cook, recently published a blog post describing FINRA’s ongoing efforts to integrate artificial intelligence (“AI”), including generative AI (“GenAI”), into its regulatory program and engage with member firms regarding their use of GenAI.  Below we highlight how FINRA is using GenAI to perform its self-regulatory functions more effectively

On September 5, 2025, the Staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission granted no-action relief that allows members of the Financial Industry Regulatory Authority, Inc. (“FINRA”) to rely on the Central Registration Depository system (“CRD”) to satisfy their record retention requirements under Rule 17a-4 under the Securities

The Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2025 Annual Regulatory Oversight Report (the “Report”), which builds on the structure and content of FINRA’s prior reports for 2021-2024. This year, the Report adds new topics relating to the third-party risk landscape, registered index-linked annuities and extended hours trading. The Report also includes new content

On February 5, 2025, Robert Cook, President and Chief Executive Officer of the Financial Industry Regulatory Industry, Inc. (FINRA), announced that FINRA will not set an effective date for its recent amendments (the “Amendments”) to Trade Reporting and Compliance Engine (TRACE) reporting rules to reduce the current 15-minute timeframe to one minute for reporting transactions

On February 7, 2025, the US Securities and Exchange Commission provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting.  Originally, the first Form SHO disclosures were due by February 14, 2025, but the exemption now pushes out the deadline to February 17, 2026 for

The Investment Company Institute (ICI) has asked the Securities and Exchange Commission (SEC) in a comment letter to delay enforcement of its new short sale disclosure rules (the “Short Sale Final Rules”) until additional compliance guidance is provided. The Short Sale Final Rules, finalized in October 2023, require certain institutional investment managers to report

On December 31, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24-18 (“RN 24-18”) to provide updated guidance to members regarding Rules 15c3-1, 15c3-3 and 17a-5 under the Securities Exchange Act of 1934 (“SEA”), Rule 204 under Regulation SHO, FINRA Rules 4210, 4230(b), 4521 and 4524, and Regulation T of the Federal

On December 20, 2024, FINRA requested public comment on its proposed rule changes to Rules 5110 (Underwriting Terms and Arrangements), 5121 (Public Offerings of Securities With Conflicts of Interest) and 5123 (Private Placements of Securities).  These proposed rule changes stem from comments received from the public in response to the May 2023 Regulatory Notice 23-09

Broker-dealers had been preparing for the sunset of the prior time-based relief that the staff of the Securities and Exchange Commission provided in respect of compliance with Rule 15c2-11 as to certain fixed income securities, which expires on January 4, 2025.  The SEC had separately provided exemptive relief with respect to Rule 144A securities; however