FINRA revised its Sanction Guidelines to
reflect, among other things, developments in FINRA's
disciplinary process and the levels of sanctions imposed during
According to FINRA Regulatory Notice 17-13, the
revisions provide (i) additional consideration for
financial exploitation of vulnerable customers, (ii) new guidelines
concerning systemic supervisory failures, short-interest reporting,
and borrowing and lending arrangements with customers, and (iii)
guidance on the potential mitigating effect of sanctions imposed by
other regulators or firm-imposed sanctions. FINRA also modified the
non-monetary and monetary range of sanctions for several guidelines
that involve "more serious violations of FINRA rules,"
and made similar changes to guidelines regarding violations that
involve unauthorized transactions.
FINRA stated that the purpose of the Sanction Guidelines is not
to provide predetermined sanctions for violations, but rather to
give adjudicators a range of appropriate sanctions for a particular
violation and let the adjudicators consider aggravating and
mitigating factors in order to arrive at a sanction based on the
relevant circumstances. FINRA initiated the review through the
National Adjudicatory Council, which is FINRA's appellate
tribunal for disciplinary cases. The revised guidelines are
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