Independent Broker Dealer Consortium

FINRA Issues New Guidance on Extraordinary Cooperation Credit

On July 11, 2019, FINRA provided long-awaited supplemental guidance on crediting member firms and individuals for extraordinary cooperation in a FINRA investigation – a practice first outlined in Regulatory Notice 08-70 (November 2008), and one for which the industry has frequently requested greater transparency and clarification. While the new guidance in Regulatory Notice 19-23 describes examples of cooperation that FINRA has considered “extraordinary,” those who have been hoping for concrete figures or ranges quantifying the effect that a firm’s extraordinary cooperation can have on a potential fine will be disappointed. 

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