Firm Element Focus

This section highlights new rules and amendments that FINRA firms may find useful to train employees on as a part of their Firm Element training.

New Rule 605 Designated Participant Authorization Form

FINRA is introducing a new electronic Rule 605 Designated Participant Authorization Form for members to obtain unique reporter identification codes and provide hyperlinks to their Rule 605 execution quality reports. The new form is available beginning June 17, 2026, through the FINRA Gateway, in advance of upcoming amendments to Rule 605 of SEC Regulation NMS and the Rule 605 NMS Plan effective August 1, 2026. All members selecting FINRA as their Designated Participant are required to submit the new form.

• FINRA Information Notice 6/17/26 (June 17, 2026): New Rule 605 Designated Participant Authorization Form

 

FINRA Adopts New Intraday Margin Standards to Replace the Day Trading Margin Requirements

FINRA has adopted new intraday margin standards to replace in their entirety the outdated day trading margin requirements, including the day trade count requirements for designating a customer as a “pattern day trader” and the $25,000 pattern day trader minimum equity requirement. The new standards—amendments to Rule 4210—will give customers more freedom to participate in the markets while also ensuring customers maintain equity in their margin account commensurate with the amount of market exposure they have at any given point in time during the trading day. This Notice provides an overview of the new intraday margin standards.

The effective date of the amendments is June 4, 2026; Phase-in Period: Ends October 20, 2027.

• FINRA Regulatory Notice 26-10 (April 20, 2026): FINRA Adopts New Intraday Margin Standards to Replace the Day Trading Margin Requirements

 

FINRA Adopts Amendments to Rule 3220 (Influencing or Rewarding Employees of Others)

As part of the FINRA Forward initiative, FINRA has adopted amendments to FINRA Rule 3220 (Influencing or Rewarding Employees of Others) to increase the gift limit from $100 to $300 per person per year; incorporate and substantially codify current guidance and interpretations; and provide for exemptive relief. FINRA has also adopted conforming amendments to raise the gift limit to $300 in Rule 2310 (Direct Participation Programs), Rule 2320 (Variable Contracts of an Insurance Company), Rule 2341 (Investment Company Securities) and Rule 5110 (Corporate Financing Rule – Underwriting Terms and Arrangements). These amendments represent a significant step toward modernizing the rules, while codifying existing guidance in a manner that will promote efficiency without reducing protection for investors.

The effective date of the amended rule is March 30, 2026.

• FINRA Regulatory Notice 26-05 2/27/2026 (March 30, 2026): FINRA Adopts Amendments to Rule 3220 (Influencing or Rewarding Employees of Others)

 

 

Reducing Burdens and Providing Guidance on the Use of Negative Consent for the Bulk Transfer or Assignment of Customers’ Accounts

In furtherance of the FINRA Forward initiative to support member compliance, this Notice reduces unnecessary burdens by eliminating the current practice of submitting draft letters for the use of negative consent to FINRA staff for review and obtaining FINRA staff’s “no objection” prior to sending the letter. In addition, the Notice consolidates guidance FINRA previously issued regarding the use of negative consent and provides members with effective practices to help guide their use of negative consent in future bulk transfers or assignments.

The effective date of the amended rule is March 30, 2026.

• FINRA Regulatory Notice 26-03 2/6/2026: Reducing Burdens and Providing Guidance on the Use of Negative Consent for the Bulk Transfer or Assignment of Customers’ Accounts

 

Final Rule: Holding Foreign Insiders Accountable Act

The SEC is adopting final amendments to certain of its rules and forms under the Securities Exchange Act of 1934 to reflect the requirements of the Holding Foreign Insiders Accountable Act. The HFIA Act amended Section 16(a) of the Exchange Act to require directors and officers of a foreign private issuer with a class of equity securities registered under Section 12 of the Exchange Act to provide disclosure of their beneficial ownership and transactions involving the issuer’s equity securities.

The effective date for this amended rule is March 18, 2026.

• Securities and Exchange Commission Final Rule 3/18/2026: Holding Foreign Insiders Accountable Act Disclosure.

 

Upcoming Trade Reporting Enhancements for Fractional Share Transactions

FINRA is reminding firms of upcoming updates to its equity trade reporting guidance in connection with enhancements to the FINRA equity trade reporting facilities to support reporting of fractional share quantities. Under the updated guidance, members engaged in fractional share trading will be required to report fractional share quantities up to six digits after the decimal. FINRA is also providing additional guidance for fractional share reporting in circumstances involving fractional amounts smaller than six decimals.

The effective date of the updated trade reporting guidance is February 23, 2026.

• FINRA Trade Reporting Notice 1/14/26 (January 14, 2026): Upcoming Trade Reporting Enhancements for Fractional Share Transaction

The Firm Element Committee would like to spotlight the following topics.

Back to Basics with FINRA’s Anti-Money Laundering (AML) E-Learning Courses

FINRA’s Anti-Money Laundering (AML) e-learning courses equip your team with the concepts and strategies needed to detect and prevent money-laundering activity — through realworld scenarios that bring typical money-laundering situations to life. The following sessions, among others, are available in the FLEX catalog:

• AML Overview
• Red Flags of Money Laundering (Registered Representatives, Operations Professionals, Institutional Sales Representatives)
• Detecting Financial Crimes: Money Laundering
• 2026 Annual AML Review

FINRA Financial Learning Experience (FLEX ®)

Cybersecurity and Privacy

Given the evolving nature, increasing frequency, and mounting sophistication of cybersecurity attacks – as well as the potential for harm to investors, firms, and the markets – cybersecurity practices are a key focus for firms and FINRA. FINRA evaluates firms’ approaches to cybersecurity risk management through reviews of their controls in areas including: technology governance, risk assessment, technical controls, access management, incident response, vendor management, data loss prevention, system change management, branch controls and staff training. Through these reviews, FINRA also assesses a firm’s ability to protect the confidentiality, integrity, and availability of sensitive customer information.

These pages are designed to assist a firm in building out its cybersecurity program by addressing the individual risks and discussing related controls needed to protect customer and firm confidential data. FINRA resources:

• In case of a Disruptive Attack or Breach
• Common Cybersecurity Threats
• Events
• Reports
• Compliance Tools
• FINRA Cybersecurity Contact

FINRA Cybersecurity Key Topic Guidance and Resources

This section provides upcoming effective dates and recently implemented dates.

FINRA Adopts Amendments to Rule 6730 (Transaction Reporting) to Streamline Allocation Reporting for BD/IAs

FINRA has amended its TRACE reporting requirements to permit a firm that is both a broker dealer and an investment adviser to report allocations of specified orders to managed customer accounts in a streamlined, aggregated manner. These amendments will take effect on June 8, 2026. FINRA is not otherwise changing its TRACE reporting requirements.

• FINRA Adopts Amendments to Rule 6730 (Transaction Reporting to Streamline Allocation Reporting for BD/IAs

 

FINRA Adopts Amendments to Extend the Trade Reporting Facilities Operating Hours 

FINRA has adopted amendments to Rules 6380A and 6380B to extend the operating hours of the FINRA Trade Reporting Facilities from opening at 8:00 a.m. Eastern Time to opening at 4:00 a.m. Eastern Time each business day. These amendments will take effect on March 30, 2026.

These amendments become effective on March 30, 2026.

• FINRA Regulatory Notice 25-15 (November 13, 2025): FINRA Adopts Amendments to Rule 6730 (Transaction Reporting) to Streamline Allocation Reporting for BD/IAs

 

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Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information

The SEC is adopting rule amendments that will require brokers and dealers (or “broker-dealers”), investment companies, investment advisers registered with the Commission (“registered investment advisers”), funding portals, and transfer agents registered with the Commission or another appropriate regulatory agency (“ARA”) as defined in the Securities Exchange Act of 1934 (“transfer agents”) to adopt written policies and procedures for incident response programs to address unauthorized access to or use of customer information, including procedures for providing timely notification to individuals affected by an incident involving sensitive customer information with details about the incident and information designed to help affected individuals respond appropriately. In addition, the amendments extend the application of requirements to safeguard customer records and information to transfer agents; broaden the scope of information covered by the requirements for safeguarding customer records and information and for properly disposing of consumer report information; impose requirements to maintain written records documenting compliance with the amended rules; and conform annual privacy notice delivery provisions to the terms of an exception provided by a statutory amendment to the Gramm-Leach-Bliley Act (“GLBA”).

The amendments became effective on August 2, 2024. The compliance date was December 3, 2025 for larger firms and is June 3, 2026 for smaller firms.

• SEC Release Nos. 34-100155; IA-6604; IC-35193; File No. S7-05-23 (June 2, 2024): Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information

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