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 various topics from last year’s report, including cybersecurity, artificial intelligence (“AI”) (including generative AI), investment and Automated Clearing House fraud, FINRA’s Remote Inspections Pilot Program, Residential Supervisory Location designation under FINRA rules, and trade reporting enhancements for fractional share transactions. Finally, the Report highlights new findings and effective practices relating to a wide range of topics covered by FINRA in prior years.
In this Legal Update, we provide a brief overview of the Report’s new topics and certain new content relating to previously covered topics.