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“FINRA Forward: A Year of Progress” Report Highlights Achievements and Foreshadows Upcoming Proposals

By Steffen Hemmerich, Marc Leong & Anna T. Pinedo on May 6, 2026
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In April 2026, FINRA published its report titled “FINRA Forward: A Year of Progress,” which provides a recap of the regulatory changes implemented by FINRA as part of its rule modernization initiative.  The report also provides insight into pending rule proposals and other policy initiatives.

Rule Changes and Guidance

FINRA highlights significant rule changes, including, among other things:

  • new intraday margin standards replacing existing day trading margin requirements;
  • amendments to rules relating to capital acquisition brokers;
  • amendments to the equity trade reporting rules to facilitate extended hours trading;
  • streamlined Trade Reporting and Compliance Engine (“TRACE”) reporting for firms that operate as both broker-dealers and investment advisers;
  • modified operation of the alternative display facility to align with Regulation NMS’s new odd-lot quotation requirements;
  • raised the gift limit to $300 (see our alert);
  • published guidance regarding the use of negative consent for bulk transfer or assignment of accounts (see our alert);
  • modernized the delivery method for requests for information and testimony to firms, shifting from mail to electronic delivery;
  • published frequently asked questions (“FAQs”) on Direct Participation Program offerings concerning discretionary transactions and limited liability companies;
  • published new and updated FAQs on distribution of institutional communications; and
  • published a FAQ regarding exemptions to fidelity bond requirements.

Pending Proposals

FINRA filed several significant rule proposals with the Securities and Exchange Commission (“SEC”) that are awaiting action.  FINRA has proposed focusing outside activities requirements on areas that present heightened risk.  Also pending before the SEC are proposals to permit performance projections to better align with standards for investment advisers under the SEC’s Marketing Rule; update corporate financing and private placement rules to facilitate capital formation; expand access to initial public offerings for collective trust funds; and expand the availability of the TRACE principal transaction indicator.

FINRA’s Board has also approved several additional rule proposals that have not yet been filed with the SEC, including proposals that would:

  • help member firms protect investors from fraud and financial exploitation;
  • make electronic delivery of customer communications the default under FINRA rules (while preserving the ability of customers to request paper deliveries);
  • shorten waiting periods before retaking qualification exams;
  • provide parties with greater input into selecting replacement arbitrators;
  • ease operational challenges relating to order allocation made by investment advisers for multiple customers; and
  • adjust reconciliation requirements for alternative investments.

Beyond formal rulemaking, FINRA identified a slate of policy initiatives in various stages of development.  FINRA is working on modernizing its rules relating to communications with the public; addressing the Remote Inspections Pilot Program; modifying branch office and residential supervisory locations requirements; further amending the equity trade reporting rules to facilitate overnight trading; and further updating corporate financing rules to promote capital formation. FINRA also plans to streamline research rules consistent with applicable statutes; issue guidance to reduce FINRA members’ customer complaint reporting burdens; and increase arbitrator compensation.  Additional items on the agenda include modifying continuing education requirements; clarifying application of the carrying agreements rule; publishing guidance regarding the payment of transaction-based compensation to personal services entities under the November 17, 2025 SEC staff no-action letter; and enhancing the equity short interest position data published on FINRA.org.

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.

Read Anna’s full bio.

Read more about Anna T. PinedoEmail
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  • Posted in:
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  • Blog:
    Free Writings + Perspectives
  • Organization:
    Mayer Brown
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