Compliance and Regulatory Alerts | 05-18-26
FINRA Forward Initiative Brings Exam Scheduling and Early Findings Options for Broker-Dealers
FINRA is making two meaningful changes to how it examines broker-dealer member firms. Announced as part of the "FINRA Forward" initiative, these updates give compliance teams more visibility and more time to respond. Here is what you need to know, and what to do next.
What Is FINRA Forward?
FINRA Forward is FINRA's ongoing initiative to modernize its operations and improve the member experience across regulatory programs. The examination process is one of its key areas of focus. The two changes described below reflect FINRA's commitment to a more transparent and collaborative approach to oversight while maintaining its risk-informed examination framework.
Change #1: Quarterly Exam Scheduling Notices
Starting in January 2026, FINRA began notifying member firms of the quarter in which they can expect to be examined. Previously, firms received relatively short notice once an examination was already underway or imminent.
Under the new process, firms receive advance notice of their examination window, giving compliance teams a meaningful runway for resource planning, document preparation, and program review. FINRA has indicated its goal is to publish the full 2027 examination schedule before quarterly announcements go out, providing even greater lead time for member firms.
Importantly, FINRA retains flexibility to conduct examinations on a risk-informed basis. The quarterly notice framework does not constrain FINRA's ability to respond to emerging issues or conduct cause examinations.
What this means for Broker-Dealers: Advance scheduling notice shifts exam preparation from a reactive scramble to a planned, manageable process. Firms that use the notification window to review their written supervisory procedures (WSPs), test their compliance controls, and prepare staff will enter examination in a much stronger position.
Change #2: Option for Early Exam Findings
FINRA now offers member firms the option to receive examination findings on a rolling basis, before the full examination concludes. Previously, findings were delivered as a consolidated report at the end of the examination cycle.
Firms that opt in can begin addressing deficiencies while the examination is still in progress. This creates two distinct advantages: it allows firms to begin corrective action sooner, and it gives them the opportunity to provide additional context or documentation to FINRA examiners before findings are finalized.
What this means for Broker-Dealers: Early findings are not a guarantee of a better outcome, but they are a strategic opportunity. Firms with mature compliance programs and responsive leadership are best positioned to take full advantage of this option. Firms that opt in but are not prepared to respond quickly and substantively may find the process more challenging
How Bates Group Helps
Bates Group provides Exam Prep Reviews and Annual Compliance Program Reviews tailored to broker-dealers and RIAs of all sizes. Our practitioners have direct experience on both sides of the regulatory relationship, and we help firms build the kind of compliance infrastructure that holds up under scrutiny.