FINRA's Special Notice issued March 17, 2026 is an invitation to member firms, investors, and other interested parties to provide input on regulatory and policy initiatives. If you've ever complained that regulators don't understand your business, this is your chance to do something about it.
What FINRA Is Asking For
FINRA is actively asking firms to weigh in on which regulatory headaches deserve attention first. The notice specifically references the organization's core mission, market integrity and investor protection, and acknowledges that effective regulation benefits from industry expertise.
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This isn't about nitpicking a draft rule. It's bigger. FINRA wants to know what should be on its radar in the first place. FINRA is soliciting input on what should be prioritized, what's working, and what isn't.
Why This Matters Operationally
Special Notices like this one shape the regulatory calendar. The topics that generate significant industry response often become the focus of future Regulatory Notices, examination priorities, and rulemaking initiatives.
Consider what happened after previous engagement efforts:
- Industry feedback on digital asset supervision influenced FINRA's guidance on crypto-related activities
- Member firm input on examination processes led to streamlined document requests
- Investor protection concerns raised during comment periods shaped suitability rule amendments
What you say here can help your compliance program down the line.
How to Participate Effectively
Generic feedback gets filed and forgotten. Specific, well-documented input gets read and considered. If you're going to respond to this Special Notice, do it right.
Focus on operational realities. Explain how current rules affect your day-to-day compliance operations. Provide specific examples. If a rule creates a disproportionate burden relative to investor protection benefit, say so and support it with data.
Address implementation challenges. FINRA writes rules; firms implement them. There's often a gap between regulatory intent and practical application. This is your opportunity to bridge that gap.
If you're going to point out a problem, bring a fix. Otherwise, your comment goes straight to the circular file.
What You Should Do
Review the full Special Notice on FINRA's website. Identify the issues most relevant to your firm's operations. Coordinate with your legal and compliance teams to develop substantive comments. Submit your input before any stated deadline.
If you're a smaller shop without a regulatory affairs team, team up with your industry group or trade association. They know how to get your voice heard.
Firms that actually engage with FINRA usually find examiners more willing to listen. No guarantees, but I've seen it play out that way more often than not.
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Key Takeaways
Is responding to this Special Notice mandatory?
No. Participation is entirely voluntary. However, this is one of the few formal mechanisms for member firms to influence regulatory priorities before they become examination focus areas or rulemaking proposals.
What topics should we address in our response?
Focus on areas where you have operational expertise and specific examples. Common topics include examination processes, technology and cybersecurity requirements, customer protection rules, and reporting obligations. The more specific and data-driven your input, the more useful it is to FINRA.
How does FINRA use the input it receives?
FINRA aggregates feedback to identify common themes and concerns across the industry. This informs their annual regulatory priorities, examination focus areas, and potential rulemaking initiatives. Significant input on specific topics often appears in subsequent Regulatory Notices.
The content in this blog is for informational purposes only and does not constitute legal advice, regulatory guidance, or an offer to sell or solicit securities. GiGCXOs is not a law firm. Compliance program requirements vary based on business model, customer base, and regulatory classification.