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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, I offer a thought on FINRA’s January 2026 edition.

“Bright Line” Cases

The January 2026 report includes the usual mix of fines, suspensions, and bars, many involving clear “bright line” violations—such as inaccurate trade reporting and failures to respond to Rule 8210 requests.

These cases are straightforward for FINRA to prosecute and offer a steady stream of enforcement opportunities.  The analysis whether a broker-dealer correctly reported trade information or a registered representative responded to a request is not nuanced—either they did or they did not.

Recommended Practices

Effective compliance in these areas requires diligence.

With respect to trade reporting, broker‑dealers should maintain a strong understanding of their data and conduct regular testing of their reporting processes.  I outline these considerations and others in A Strategy for Creating an Effective CAT Compliance Program, available as a free download.

Registered representatives should generally respond to FINRA inquiries under most circumstances.  Accepting an industry bar for a Rule 8210 violation—one of the simplest violations for FINRA to prove—can lead to significant collateral consequences, including potential “bad actor” disqualifications under certain SEC rules.  Regulators in other industries also generally take note given the information on BrokerCheck.  Responding to FINRA is costly and time-consuming, but is generally worth the effort.

Please contact me if you would like to discuss.

Because broker-dealers, registered investment advisers and their representatives want to spend their time serving their clients, not their regulators.

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