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ARTICLE · 17 JULY 2019

FINRA Issues New Guidance On Credit For Extraordinary Cooperation

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FINRA also highlighted examples of recent enforcement actions in which credit was given to respondents.

United StatesFinance and Banking
Paul Eckert
Paul Eckert
Christopher David
Christopher David
Bruce Newman
Bruce Newman
Elizabeth Mitchell
Elizabeth Mitchell
Jonathan S. Pressman
Jonathan S. Pressman
Nicole Rabner
Nicole Rabner
Daniel F. Schubert
Daniel F. Schubert
Ashley E. Bashur
Ashley E. Bashur
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Overview

On July 11, 2019, the Financial Industry Regulatory Authority ("FINRA") restated and supplemented prior guidance regarding the circumstances under which FINRA will award credit for "extraordinary cooperation" in investigations and the nature of credit available.1   This guidance comes more than 10 years after FINRA last provided formal guidance on this issue. Although the new guidance does not alter the criteria FINRA uses to assess cooperation, it clarifies the difference between required cooperation and extraordinary cooperation and provides significantly more transparency into FINRA's assessment of conduct meriting extraordinary cooperation credit. In particular, FINRA noted the importance of broad and prompt corrective measures, customer restitution, and substantial assistance to FINRA.

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