August 17, 2017

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National Adjudicatory Council Revises Sanction Guidelines

The Financial Industry Regulatory Authority, through the National Adjudicatory Council (NAC), has revised the FINRA Sanction Guidelines that hearing panels and the NAC use in determining appropriate remedial sanctions for FINRA members in disciplinary proceedings. Among other changes, the revised Sanction Guidelines include the following additions:

  • three new guidelines: Supervision—Systemic Supervisory Failures, Borrowing From or Lending to Customers and Short Interest Reporting;

  • a new general principle examining the mitigating effects of regulatory or firm-imposed sanctions and corrective action;

  • a new factor considering whether a respondent has exercised undue influence over a customer;

  • revised sanctions for more serious FINRA rule violations; and

  • other conforming changes.

The new guidelines were effective immediately upon publication. More details are available in FINRA Regulatory Notice 17-13.

©2017 Katten Muchin Rosenman LLP


About this Author

Janet M. Angstadt, Securities Lawyer, Katten Muchin

Janet M. Angstadt is the head of Katten's Chicago Financial Services practice. She focuses her practice on broker-dealer and exchange compliance issues and advises companies on matters regarding compliance with the regulations of the US Securities and Exchange Commission (SEC) and self-regulatory organizations (SROs).

Janet represents clients in a wide range of legal and regulatory matters, including mergers and acquisitions, SRO investigations, compliance issues related to registrations, sales practice, short sales, Regulation NMS, market-making and...

Laura Krcmaric, Financial Services Attorney, Katten Law Firm

Laura Krcmaric represents clients in the financial services industry, focusing on regulatory and compliance work. Prior to joining Katten, Laura served as counsel for Credit Suisse, where she provided advice to the private banking and wealth management division. She also was an honors intern with the Securities and Exchange Commission.

While in law school, Laura served as a staff member and symposium editor for the North Carolina Law Review. She also was a member of the Community Development Law Clinic, representing nonprofit organizations.