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FINRA Provides Guidance on the Use of Negative Consent for Bulk Transfers of Customer Accounts and Discontinues Related Prior Review Process

By Steffen Hemmerich, Anna T. Pinedo, Joshea Mark & Stephen Vogt on February 17, 2026
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The Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 26-03 (the “Notice”) consolidating guidance on the use of negative consent letters for bulk transfers or assignments of customer accounts between FINRA members. Moreover, the Notice eliminates the current practice of submitting draft negative consent letters to FINRA staff for review; this change will become effective on April 1, 2026.  

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Photo of Anna T. Pinedo Anna T. Pinedo

Anna Pinedo is a partner in Mayer Brown’s New York office and a member of the Corporate & Securities practice. She concentrates her practice on securities and derivatives. Anna represents issuers, investment banks/financial intermediaries and investors in financing transactions, including public offerings and…

Anna Pinedo is a partner in Mayer Brown’s New York office and a member of the Corporate & Securities practice. She concentrates her practice on securities and derivatives. Anna represents issuers, investment banks/financial intermediaries and investors in financing transactions, including public offerings and private placements of equity and debt securities, as well as structured notes and other hybrid and structured products.

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  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Free Writings + Perspectives
  • Organization:
    Mayer Brown
  • Article: View Original Source

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