On January 22, 2026, the Financial Industry Regulatory Authority, Inc. (“FINRA”) filed a proposed rule change with the Securities and Exchange Commission (“SEC”) to amend FINRA Rule 5123, which governs member filings in connection with private placements. The proposal would expand the rule’s existing accredited investor exemption to cover certain family offices and to include
FINRA Publishes Report on Social Media‑Influenced Investing
On December 11, 2025, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued a report on social media‑influenced investing (the “Report”). FINRA observes that an increasing number of investors report that social media content directly impacts their investing decisions; this trend is especially pronounced among younger investors. The Report summarizes the findings of a FINRA staff…
FINRA Publishes 2026 Annual Regulatory Oversight Report
The Report highlights FINRA’s continued focus on generative artificial intelligence, cybersecurity, small-cap securities fraud, and third-party risk
The Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2026 FINRA Annual Regulatory Oversight Report (the “Report”), which builds on the structure and content of FINRA’s prior reports for 2021-2025. This year, the Report was published earlier than…
FINRA Initiates Targeted Review of Practices Relating to Small-Capitalization Offerings
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 Advances Regulatory Mission Through Artificial Intelligence
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…
SEC Grants No-Action Relief from Rule 17a-4 for Reliance on Central Registration Depository System to Maintain Electronically Signed Form U4 Filings
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…
FINRA Publishes 2025 Annual Regulatory Oversight Report
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…
FINRA Will Not Set an Effective Date for Amendments to TRACE Rules Establishing One-Minute Reporting Requirement; FINRA to Prepare New Filing for Public Comment
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…
SEC Grants Temporary Exemption from Rule 13f-2 and Form SHO Compliance
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…
ICI Urges SEC to Delay Short-Sell Reporting Rules Amid Compliance Uncertainty
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…

