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ARTICLE · 29 MAY 2026

Structured Notes, Unstructured Compliance Risks: FINRA Wants To Know If Your Firm Has A Plan

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.

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On May 19, 2026, the Financial Industry Regulatory Authority (“FINRA”) announced that it is conducting a targeted review of how member firms supervise the sale of higher-risk structured products.

United StatesFinance and Banking
Edmund Daley
Edmund Daley
Pete S. Michaels
Pete S. Michaels
Elizabeth Platonova
Elizabeth Platonova
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On May 19, 2026, the Financial Industry Regulatory Authority (“FINRA”) announced that it is conducting a targeted review of how member firms supervise the sale of higher-risk structured products. FINRA is particularly focused on non-principal protected “worst-of” structured notes and has announced it will be sending sweep letters to targeted firms. This announcement, combined with recent high-profile settlements involving structured notes, sends a clear message: firms that treat these complex instruments as routine offerings do so at their own risk. Because FINRA is putting the spotlight on structured notes, and we anticipate other high-risk products, firms need to take steps now to ensure they stay ahead of this enforcement priority. 

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