FINRA President and CEO Robert Cook Provides Update on ‘FINRA Forward’ at the SIFMA Compliance & Legal 2026 Annual Conference

Financial Industry Regulatory Authority (FINRA) President and CEO Robert Cook spoke at the 2026 SIFMA Compliance & Legal Annual Conference, outlining FINRA's strategic priorities, ongoing initiatives, and the direction of regulatory policy under the "FINRA Forward" agenda. Cook emphasized that effective regulation by a modern regulator begins with organizational culture, noting that FINRA must cultivate a culture that is inquisitive, committed to continuous learning, and open to engaging with member firms.

Reviewing and Enhancing FINRA Enforcement 

Cook noted that FINRA's external review of its enforcement program, conducted with outside consultants, is nearing completion, with the resulting report expected in the second quarter of 2026. Certain procedural enhancements have previously been announced (read Katten’s summary here). Cook explained that the review was focused on ensuring the enforcement function is appropriately organized, transparent, and governed. He noted that some of the forthcoming recommendations may be implemented promptly, while others will require additional deliberation.

Reforms to FINRA Arbitration 

Cook addressed FINRA's recently published regulatory notice soliciting comments on changes to its arbitration forum (read Katten’s summary here). Cook described the regulatory notice as deliberately thorough, incorporating background on relevant statutes, Supreme Court precedent, and prior Securities and Exchange Commission (SEC) statements. He encouraged commentators to engage with the historical record in their comments and explain why circumstances may now warrant changes not previously adopted. Cook also noted that some of the proposed changes, such as those related to punitive damages, would historically have impacted a very small portion of cases and presented FINRA with the opportunity to make changes while preserving the core of the arbitration program.

Modernizing Rules and Upcoming Changes to E-Delivery and Communications Retention Requirements

As part of FINRA’s ongoing efforts to modernize its rules, Cook noted that the FINRA Board approved a proposal to make electronic delivery the default for investor communications, with investor protections including the ability to opt out or to maintain the current structure. On off-channel communications, Cook described FINRA's approach as focused on whether firms maintain reasonable policies and procedures to comply with existing rules, acknowledging that even robust compliance programs may not prevent every instance of individual noncompliance. FINRA will continue to bring cases where there is evidence of underlying misconduct or a genuine breakdown in supervisory oversight, and will support the SEC's approach. Cook noted the industry would benefit from greater clarity on enforcement expectations, including whether specific red flags should be required before a firm is expected to image a device. Cook also detailed that FINRA will publish a quarterly regulatory policy agenda, modeled after the SEC’s regulatory flexibility agenda, to provide market participants with greater transparency into FINRA's active workstreams. The agenda has been shaped by comment letters and direct engagement with trade associations and member firms, and Cook stated FINRA intends to adhere to the stated deadlines. More than 20 initiatives are currently underway, and the agenda will include timeframes and status updates for each. 

Enhancing Member Firm Compliance

Cook reported meaningful progress on efforts to reduce regulatory burdens and provide member firms with better compliance tools and resources. Over the prior years, FINRA had taken steps to limit information requests to clients, reducing blotter requests by 50 percent and blue sheet requests by 70 percent. FINRA is also piloting an internal library to catalog previously collected policies and procedures, reducing duplicative requests across examination groups. On compliance tools, Cook noted that FINRA recently released a new Regulation M report card, with plans to generate report cards more frequently and to provide additional training resources. In the examination space, FINRA is extending its backstop examination cycle from every four years to every six years for lower-risk firms, while continuing to monitor them through other means. Cook noted that FINRA will provide member firms more advanced notice and scheduling flexibility for examinations and will publish its risk standards.

Cybersecurity and Third-Party Fraud

Cook highlighted third-party fraud, cyber fraud, and artificial intelligence (AI)-enabled fraud as major areas of focus and opportunities for industry-wide collaboration. Current efforts include tabletop exercises, information-sharing bulletins, and vendor surveys to give firms advanced warning of emerging risks. FINRA will also be rolling out a financial intelligence fusion center, allowing firms to report threats and receive actionable intelligence in return. Cook encouraged firms to proactively engage with FINRA to keep the organization in the flow of real-time threat information.