By taxclubadmin 
The Financial Industry Regulatory Authority conducted the fewest disciplinary cases in at least a decade in 2025, a year when it embarked on procedural reforms intended to create more transparency and communication with broker/dealers, according to an annual analysis by the Washington D.C.-based law firm Eversheds Sutherland LLP.
In 2025, FINRA returned to a trend toward a smaller caseload, reporting 431 disciplinary actions from FINRA online actions, the lowest by that measure since Eversheds Sutherland started tracking in 2015. In 2024, disciplinary online actions increased for the first time since 2020.
The decrease came in a year when FINRA started implementing “substantial procedural reforms” that have extended into early 2026, according to report authors Brian Rubin, co-head of the law firm’s securities enforcement practice, and Adam Pollet, co-head of its global digital assets and cryptocurrency group.
“These reforms include a series of enhancements to FINRA’s Enforcement process designed to promote earlier engagement, greater transparency and more constructive dialogue with firms,” the authors wrote.
Despite the decline in disciplinary actions, FINRA collected 27% more in fines last year. The jump, however, was partly due to a large $26 million payment by Robinhood Financial and Robinhood Securities for alleged violations dating back to 2014. FINRA charged the entities with incomplete disclosures and failure to implement proper anti-money laundering practices. Robinhood neither admitted nor denied the charges.
Taking out that large fine, FINRA’s total take-home for the year would have been down 15% year-over-year, the authors noted, while also finding that larger fines were generally down in 2025.
Eversheds Sutherland also includes FINRA’s full-year statistical reporting on disciplinary actions, which include tracking such as minor rule violations. Those tallies are higher, though they have also been decreasing over the years, and the law firm noted that the full 2025 year statistics are not yet complete.
The law firm’s analysis examines FINRA’s monthly disciplinary releases, press releases and online databases to compile an annual running tally of the firm’s actions.
In their analysis, the duo also ranked the top five regulatory issues by total fines.
In 2025, those were: 1) anti-money laundering; 2) misleading, inaccurate or unbalanced communications; 3) trade reporting issues; 4) recordkeeping missteps; and 5) Regulation Best Interest cases.
2025 was the first time in the past five years that communication issues hit the top five, according to the analysts. FINRA reported 12 cases of misleading communications that led to $6.5 million in fines.
“These cases dealt with a variety of communications, including the use of social media and communications regarding crypto assets,” the authors wrote.
In one case, “FINRA found that certain influencer communications were not fair and balanced and included exaggerated and promissory statements. The firm also failed to review and approve all influencers’ posts and failed to preserve records of those posts.”
Eversheds Sutherland also noted that Reg BI cases remain a focus area for the regulator, which is supervised by the Securities and Exchange Commission.
The authors said Reg BI cases fell into three categories of investigation.
The first was in product and strategy recommendations by broker/dealers, including failures to properly supervise recommendations on complex and high-risk investment products, failure to properly supervise exchanges for variable annuities and registered index-linked annuities, and failure to properly supervise on opening commission-based accounts with an additional fee for services such as financial planning.
The authors also noted FINRA’s interest in deficient written supervisory procedures—including when broker/dealers rely on “boilerplate” procedures.
Finally, it noted FINRA’s sanctioning of firms for failing to file or deliver a customer relationship summary form to customers, or for omitting material facts from the Form CRS.
If FINRA’s reforms are implemented, these and other investigations should be more transparent for firms and allow for more engagement during the process.
“FINRA is imposing what it calls ‘common sense improvements,’” Rubin said in a statement with the report. “Neither firms nor FINRA wants to focus on process issues for their own sake. Instead, enforcement investigations should focus on core questions, such as: Were rules violated? Were violations intentional? And was anyone harmed?”