The Financial Industry Regulatory Authority, Inc. (FINRA) posts the disciplinary actions it took to an online database. It also publishes a monthly summary of these actions, which is a worthwhile read for those in the industry – if only for insight into FINRA’s priorities. Below is a thought on FINRA’s December 2025 edition.
Supervisory Systems Always Matter
Several December 2025 cases—the first four and five of the first seven—involved alleged supervisory system failures, underscoring how many FINRA or SEC violations trace back to weak procedures or controls.
Recommended Actions
Both broker-dealers and registered investment advisers should regularly review and test their policies and procedures to ensure they align with current business practices and can be effectively followed. Ineffective procedures are worse than having none. Drafting procedures is not easy as it is part art and part science. Additional guidance is at 6 Tips for Writing Supervisory Procedures – The ABCs, which is also available as a free download.
Please contact me if you would like to discuss strengthening your firm’s supervisory systems.
Because broker-dealers, registered investment advisers and their representatives want to spend their time serving their clients, not their regulators.