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ARTICLE · 17 OCTOBER 2022

Six Takeaways From FINRA's Revised Sanction Guidelines

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The Financial Industry Regulatory Authority (FINRA) Sanction Guidelines have been significantly revised, now giving FINRA discretion to impose considerably higher fines on mid- and large-size firms.

United StatesFinance and Banking
Susan Light
Susan Light
Michael Lohnes
Michael Lohnes
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The Financial Industry Regulatory Authority (FINRA) Sanction Guidelines have been significantly revised, now giving FINRA discretion to impose considerably higher fines on mid- and large-size firms. The revisions, published on September 29, also deleted 20 prior infrequently used guidelines.

The Sanction Guidelines help FINRA adjudicators determine the appropriate penalty for FINRA rules violations. The guidelines are not absolute requirements; instead, they suggest a range of appropriate penalties before considering aggravating and mitigating circumstances. Firms and individuals may equally refer to the guidelines when settling disciplinary matters.

FINRA stated that its revisions "ensure that guidelines accurately reflect the level of sanctions imposed... in disciplinary proceedings." However, FINRA's FAQs emphasize that the sanctions imposed in both litigated and settled matters may fall above or below the recommended ranges.

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