# SECURITIES AND EXCHANGE COMMISSION

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URL: https://www.frixlaw.com/law-library/documents/agency%3Asec%3A2cad075cfa4d398e

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-106410; File No. SR-FINRA-2026-020]
Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of
Filing and Immediate Effectiveness of a Proposed Rule Change to Modify the
Implementation Schedule of Amendments to Schedule A to the FINRA By-Laws Adopted
in SR-FINRA-2024-019 as Modified in SR-FINRA-2025-007
September 18, 2026.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 (“Act”)1 and Rule
19b-4 thereunder,2 notice is hereby given that on September 15, 2026, the Financial Industry
Regulatory Authority, Inc. (“FINRA”) filed with the Securities and Exchange Commission
(“SEC” or “Commission”) the proposed rule change as described in Items I, II, and III below,
which Items have been prepared by FINRA. FINRA has designated the proposed rule change as
“establishing or changing a due, fee or other charge” under Section 19(b)(3)(A)(ii) of the Act3
and Rule 19b-4(f)(2) thereunder,4 which renders the proposal effective upon receipt of this filing
by the Commission. The Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.

1

15 U.S.C. 78s(b)(1).

2

17 CFR 240.19b-4.

3

15 U.S.C. 78s(b)(3)(A)(ii).

4

17 CFR 240.19b-4(f)(2).

I.

Self-Regulatory Organization’s Statement of the Terms of Substance of the Proposed
Rule Change
FINRA is proposing to modify the implementation schedule of amendments adopted in

SR-FINRA-2024-019, as modified in SR-FINRA-2025-007, with respect to the adjustment of
FINRA fees to provide sustainable funding for FINRA’s regulatory mission.
The text of the proposed rule change is available on FINRA’s website at
http://www.finra.org and at the principal office of FINRA.
II.

Self-Regulatory Organization’s Statement of the Purpose of, and Statutory Basis for, the
Proposed Rule Change
In its filing with the Commission, FINRA included statements concerning the purpose of

and basis for the proposed rule change and discussed any comments it received on the proposed
rule change. The text of these statements may be examined at the places specified in Item IV
below. FINRA has prepared summaries, set forth in sections A, B, and C below, of the most
significant aspects of such statements.
A.

Self-Regulatory Organization’s Statement of the Purpose of, and Statutory Basis
for, the Proposed Rule Change
1.

Purpose

Background
In November 2024, FINRA filed for immediate effectiveness a proposed rule change to
increase the revenues that FINRA, as a not-for-profit self-regulatory organization, relies upon to
fund its regulatory mission.5 The fees raised related to FINRA’s core regulatory functions as
well as select fees related to the use of FINRA programs and services and were designed to

5

See Securities Exchange Act Release No. 101696 (November 21, 2024), 89 FR 93709
(November 27, 2024) (Notice of Filing and Immediate Effectiveness of File No. SRFINRA-2024-019) (“2024 Fee Filing”).
2

closely align FINRA’s revenues with its projected costs. The fee increases would be phased in
gradually over a five-year period from 2025 through 2029.6
Over recent years, FINRA’s operating revenues have increased significantly—well
beyond projections—and may continue increasing in the coming years. This revenue increase is
driven by a combination of higher average daily trading volume, higher member revenues, and
the impact of the 2024 Fee Filing. 7
In addition, FINRA’s expenses have been reduced. In 2025, FINRA undertook a
strategic realignment to enhance the efficiency and effectiveness of its operations. This
realignment is consistent with FINRA’s commitment to a culture of continuous improvement
with a rigorous focus on carefully managing costs and identifying new efficiency opportunities
where consistent with its mission. Among other changes, this included the consolidation of
Enforcement, Member Supervision and Market Oversight functions into a new Regulatory
Operations department; the consolidation of certain market services and utility functions into a
new Market & Regulatory Services department; leveraging innovative technology throughout
our regulatory program; a voluntary buyout for staff; and other organizational changes and

6

See supra note 5. For operational reasons and to give members and issuers additional
time to budget and plan, FINRA modified the implementation schedule for two of the fee
changes adopted in the 2024 Fee Filing: (i) the new fee related to review of private
placements submitted to FINRA’s Corporate Financing Department (“Corporate
Financing”) (the “Corporate Financing Private Placement Review Fee”); and (ii) the
increases to the fee caps related to review of public offerings submitted to Corporate
Financing (the “Corporate Financing Public Offering Review Fee”). Implementation of
those fees was postponed from July 1, 2025 to January 1, 2027. See Securities Exchange
Act Release No. 103232 (June 11, 2025), 90 FR 25684 (June 17, 2025) (Notice of Filing
and Immediate Effectiveness of File No. SR-FINRA-2025-007).

7

See FINRA, 2026 Annual Budget Summary,
https://www.finra.org/sites/default/files/2026-04/2026-finra-annual-budget-summary.pdf.
3

enhancements.8 This realignment has been primarily responsible for a ten percent budgeted
expense reduction for fiscal year 2026. 9
FINRA actively monitors its reserves and takes action as appropriate to address potential
surpluses (or reserve levels above target). 10 In response to higher-than-anticipated fees received
in 2025 and 2024, FINRA rebated $100 million of 2025 fees in March 2026, and rebated $50
million of 2024 fees in 2025.11 FINRA is also prepared to further address revenue surpluses in
2026.
However, looking forward, if FINRA implements the remaining fee increases as
scheduled, FINRA anticipates that its revenues will continue to exceed its expenses, resulting in
excess reserve levels beyond those targeted under the Financial Guiding Principles.12 Therefore,

8

See supra note 7.

9

See supra note 7.

10

See supra note 7. FINRA’s Financial Guiding Principles explain the extent to which
FINRA relies on its financial reserves—originally derived from the sale of Nasdaq—to
help support its regulatory mission. See FINRA’s Financial Guiding Principles,
https://www.finra.org/sites/default/files/finra_financial_guiding_principles_0.pdf.
Information about FINRA’s financial reserves is provided each year in FINRA’s
published annual financial reports. See FINRA Financial Reports and Policies, available
at https://www.finra.org/about/annual-reports. FINRA strives to maintain an appropriate
level of reserves, which the FINRA Board of Governors has determined to be at least one
year of expenditures.

11

See FINRA, 2026 Annual Budget Summary supra note 7.

12

As explained in the 2024 Fee Filing, FINRA has made—and continues to make—
reasonably conservative assumptions using a variety of information points, including
historical data and anticipated trends. If key assumptions change materially, FINRA
would consider various modifications as appropriate, including further fee rebates,
reducing future fees in a manner that preserves FINRA’s ability to support the demands
of its mission, or investing in FINRA’s operations to continue to meet the demands of the
modern marketplace. See 2024 Fee Filing, supra note 5; FINRA, 2026 Annual Budget
Summary, supra note 7.
4

FINRA is now proposing to modify the implementation schedule for the remaining fee increases
by delaying the implementation of those fee changes by two years.
Proposal
The proposed rule change would postpone for two years implementation of all fee
changes adopted in the 2024 Fee Filing scheduled to take effect between January 1, 2027 and
January 1, 2029. This includes the following core regulatory fees: Gross Income Assessment (or
GIA), Trading Activity Fee (or TAF), Personnel Assessment (or PA), Branch Office System
Processing Fee, Registration Fees, System Processing, and Renewal Late Fee. It also includes
two use-based fees: Corporate Financing Private Placement Review Fee and Corporate
Financing Public Offering Review Fee. 13
During the two-year postponement, members would be charged at the 2026 rates. The
postponement would result in the following implementation schedule for the remaining fee
changes:
•

On January 1, 2029, the previously adopted 2027 fee changes would take effect;

•

On January 1, 2030, the previously adopted 2028 fee changes would take effect; and

•

On January 1, 2031, the previously adopted 2029 fee changes would take effect. 14

13

The Corporate Financing-related fees are scheduled to be implemented beginning on
January 1, 2027. See supra note 6. This proposed rule change does not impact the
following fees raised in the 2024 Fee Filing that were fully implemented in 2025 or 2026:
Advertising Regulation Review, Branch Office Registration, Dispute Resolution Services
Arbitration, Regulation T and Exchange Act Rule 15c3-3(n) Requests for Extension of
Time, Continuing Education Regulatory Element, Late Disclosure, and Qualification
Examination.

14

FINRA includes the 2031 rates for completeness when comparing this proposed rule
change (2027 to 2031) to the 2024 Fee Filing (2025 to 2029). FINRA notes, however,
that no rate changes will occur in 2031 as compared to the 2024 Fee Filing (i.e., under the
2024 Fee Filing, the 2029 rates would have applied in 2031, as they would under this
proposed rule change).
5

The postponed revenue collection resulting from the proposed rule change would result in
member savings as compared to the 2024 Fee Filing. Savings for members is measured as the
difference between the total revenue expected to be collected from the member under the fee
changes adopted in the 2024 Fee Filing over the four-year transitional period (i.e., 2027 through
2030) and the total expected to be collected from the member according to this proposed rule
change over the same period. The median savings rate 15 for all members would be 7.2%,
representing approximately $718 million in total savings to members over the four-year
transitional period. As discussed further below, the estimated savings rates for FINRA members
would be similar for members based on firm size and business model. The savings accrue over
only the four-year transitional period, as under the proposed rule change the fee rates in 2031 and
later years would be the same as under the 2024 Fee Filing.
The proposed rule change would allow FINRA to maintain its reserve balance at its target
level based on FINRA’s projected revenue and costs, 16 while preserving the equitable allocation
of fees adopted in the 2024 Fee Filing. 17

15

The savings rate for a member is its savings divided by the total revenue expected to be
collected from the member under the fee changes adopted in the 2024 Fee Filing over the
four-year transitional period.

16

Anticipated costs would not include potential costs associated with new services that may
be initiated or approved in the future. FINRA may submit separate fee filings to cover
program costs for new services.

17

FINRA has explained that numerous operations and services must be funded by general
revenue sources, which include both core regulatory and other use-based fees. FINRA’s
current fee structure is designed to ensure sufficient funding to meet all of its regulatory
obligations in a manner that equitably allocates fees among FINRA members,
notwithstanding the fluctuations in different revenue streams and cost drivers that are
naturally expected to occur over time. The Commission has historically agreed that this
overall cost-based pricing structure “is reasonable in that it achieves a generally equitable
impact across FINRA’s membership and correlates the fees assessed to the regulatory
services provided by FINRA.” See Securities Exchange Act Release No. 61042
6

The proposed implementation schedule for each specific fee is described below.
Gross Income Assessment*
Tier
(Revenue)

2026
(current)

2027 (no
change)

2028 (no
change)

2029

2030

2031

$0 to $1
$1,200
$1,200
$1,200
$1,200
$1,200
$1,200
million
Greater than
0.1827% 0.1827%
0.1827% 0.2056% 0.2280% 0.2280%
$1 million up
to $25 million
Greater than
0.3909% 0.3909%
0.3909% 0.4397% 0.4877% 0.4877%
$25 million up
to $50 million
Greater than
0.0779% 0.0779%
0.0779% 0.0876% 0.0972% 0.0972%
$50 million up
to $100
million
Greater than
0.0549% 0.0549%
0.0549% 0.0618% 0.0685% 0.0685%
$100 million
up to $5
billion
Greater than
0.0597% 0.0597%
0.0597% 0.0672% 0.0745% 0.0745%
$5 billion up
to $25 billion
Greater than
0.1286% 0.1286%
0.1286% 0.1447% 0.1604% 0.1604%
$25 billion
*Section 1(c) of Schedule A to the FINRA By-Laws sets forth the GIA.
Trading Activity Fee*
Security
Type

2026
(current)

2027 (no
change)

2028 (no
change)

2029

2030

2031

Covered
Equity
Security

$0.000195
per share (up
to $9.79 max
per trade)

$0.000195
per share (up
to $9.79 max
per trade)

$0.000195
per share (up
to $9.79 max
per trade)

$0.000232
per share (up
to $11.61
max per
trade)

$0.000240
per share (up
to $12.05
max per
trade)

$0.000249
per share (up
to $12.50
max per
trade)

(November 20, 2009), 74 FR 62616, 62620 (November 30, 2009) (Order Approving File
No. SR-FINRA-2009- 057); see also 2024 Fee Filing supra note 5.
7

Options

$0.00329 per
contract

$0.00329 per
contract

$0.00329 per
contract

$0.00390 per
contract

$0.00404 per
contract

$0.00420 per
contract

Security
Future

$0.000135
per contract
(with $0.016
minimum per
round trip
transaction)

$0.000135
per contract
(with $0.016
minimum per
round trip
transaction)

$0.000135
per contract
(with $0.016
minimum per
round trip
transaction)

$0.00016 per
contract
(with $0.019
minimum per
round trip
transaction)

$0.000166
per contract
(with $0.020
minimum per
round trip
transaction)

$0.000172
per contract
(with $0.021
minimum per
round trip
transaction)

TRACEEligible
Security
(Other
than
AssetBacked
Security)
or
municipal
security
TRACEEligible
AssetBacked
Security

$0.00124 per
bond (up to
$1.24 max
per trade)

$0.00124 per
bond (up to
$1.24 max
per trade)

$0.00124 per
bond (up to
$1.24 max
per trade)

$0.00147 per
bond (up to
$1.47 max
per trade)

$0.00153 per
bond (up to
$1.53 max
per trade)

$0.00158 per
bond (up to
$1.58 max
per trade)

$0.00000124
times
reported
value (up to
$1.24 max
per trade)

$0.00000124
times
reported
value (up to
$1.24 max
per trade)

$0.00000124
times
reported
value (up to
$1.24 max
per trade)

$0.00000147
times
reported
value (up to
$1.47 max
per trade)

$0.00000153
times
reported
value (up to
$1.53 max
per trade)

$0.00000158
times
reported
value (up to
$1.58 max
per trade)

*Section 1(b) of Schedule A to the FINRA By-Laws sets forth the TAF. Many members identify
that they pass through TAF to customers.
Personnel Assessment*
Tier (No. of
Reps)

2026

2027 (no
change)

2028 (no

(current)

2029 2030 2031

change)

Reps 0-5

$245

$245

$245

$260 $270 $295

Reps 6-25

$235

$235

$235

$250 $260 $285

8

Reps 26 and
greater

$225

$225

$225

$240 $250 $275

*Section 1(e) of Schedule A to the FINRA By-Laws sets forth the PA.
Branch Office System Processing Fee*
Fee

2026
(current)

2027
(no
change)
$75

2028
(no
change)
$75

2029 (no
change)

2030

2031

Branch Office System
$75
$75
$105 $105
Processing Fee (initial and
annual)
*Section 4(a)(1) and (2) of Schedule A to the FINRA By-Laws sets forth the Branch
Office System Processing Fee (initial and annual).
Registration Fees*
Fee

2026
(current)

Initial/Transfer Registration
Form U4 filing

$125

Termination U5 filing

$50 (plus
$100 if
late filed)

Disclosure review
Electronic Fingerprinting

$155
$20

2027
(no
change)
$125

2028 (no
change)

2029 (no 2030
change)

2031

$125

$125

$175

$175

$50
(plus
$100 if
late
filed)
$155
$20

$50 (plus $50
$100 if
(plus
late filed) $100 if
late
filed)
$155
$155
$20
$20

$70
(plus
$140
if late
filed)
$215
$28

$70
(plus
$140 if
late
filed)
$215
$28

Non-Electronic
$30
$30
$30
$30
$42
$42
Fingerprinting
Fingerprinting Processed
$30
$30
$30
$30
$42
$42
Through Another SRO
*Section 4(b)(1)-(6) of Schedule A to the FINRA By-Laws sets forth Registration Fees.
FINRA also proposes conforming changes to Section 15(g) of Schedule A to the FINRA
By-Laws to align this proposed fee change with the same fees for Funding Portal
members.
Renewal Late Fee*
The Renewal Late Fee is 10 percent of a member’s cumulative final renewal statement
with the following minimums and maximums:

9

Fee

2026
(current)

2027 (no
change)

2028 (no
change)

2029 (no
change)

2030

2031

The minimum late
$100
$100
$100
$100
$140
$140
fee FINRA will
assess is
The maximum late
$5,000
$5,000
$5,000
$5,000
$7,000 $7,000
fee FINRA will
assess is
*Section 4(b)(8) of Schedule A to the FINRA By-Laws sets forth the Renewal Late Fee.
System Processing Fee*
Number of securities
2026
2027 (no 2028
2029
2030
2031
regulators with which
(current)
change)
(no
(no
each registered person
change) change)
of a member is
registered, excluding
registration as an
investment adviser
representative
1-5
$70
$70
$70
$70
$100
$100
6-20
$95
$95
$95
$95
$125
$125
21-40
$110
$110
$110
$110
$140
$140
41+
$125
$125
$125
$125
$155
$155
*Section 4(b)(7) of Schedule A to the FINRA By-Laws sets forth the System Processing
Fee.
Corporate Financing Private Placement Review Fee*
Private
2026
2027 (no
2028 (no
2029
2030
2031
Placements (current) change)
change)
(Offerings
>$25M)
Flat Fee
$0
$0
$0
$300
$300
$300
% of
0%
0%
0%
0.008%
0.008%
0.008%
Offering
Offering
$0
$0
$0
$500
$500
$500
Cap
million
million
million
*Section 7(c) of Schedule A to the FINRA By-Laws would set forth the Corporate
Financing Private Placement Review Fee. This fee would apply only to private
placement offerings of greater than $25 million and would be capped at $40,300 (0.008%
of $500,000,000 offering + $300 flat fee). FINRA believes that this fee would be paid
for by, or passed through to, issuers.

10

Corporate Financing Public Offering Review Fee Cap*
2026
(current)
$225,000

2027 (no
change)
$225,000

2028 (no
change)
$225,000

2029

2030

2031

Non$1,125,000 $1,125,000 $1,125,000
WKSI**
WKSI
$225,000 $225,000
$225,000
$389,000
$467,000
$560,000
*Section 7(a)-(b) of the Schedule A to the FINRA By-Laws sets forth the Corporate
Financing Public Offering Review Fee. FINRA believes that this fee is paid for by, or
passed through to, issuers.
**WKSI stands for Well Known Seasoned Issuer. The Commission recently proposed to
eliminate the WKSI definition (as it relates to all issuers other than foreign private
issuers) and establish two new categories of issuers: Eligible Listed Issuer and Seasoned
Eligible Listed Issuer, both of which would be defined in Rule 405. See Registered
Offering Reform, Securities Exchange Act Release No. 105513 (May 19, 2026), 91 FR
31022 (May 26, 2026). If these proposed changes are finalized, FINRA will consider if
any changes to its fees are appropriate.
FINRA has filed the proposed rule change for immediate effectiveness. The effective
date and the implementation date will be the date of filing. The proposed rule change would
modify the previously adopted fee implementation schedule as follows: from January 1, 2027
through December 31, 2028, fees would remain at 2026 rates; implementation of fees scheduled
to begin on January 1, 2027 would instead commence on January 1, 2029; implementation of
fees scheduled to begin on January 1, 2028 would instead commence on January 1, 2030; and
implementation of fees scheduled to begin on January 1, 2029 would instead commence on
January 1, 2031.18

18

FINRA notes that the proposed rule change would impact all members, including
members that are funding portals or have elected to be treated as capital acquisition
brokers (“CABs”), given that the funding portal and CAB rule sets incorporate the
impacted FINRA rules by reference.
11

2. Statutory Basis
FINRA believes that the proposed rule change is consistent with the provisions of Section
15A(b)(5) of the Act,19 which requires, among other things, that FINRA rules provide for the
equitable allocation of reasonable dues, fees and other charges among members and issuers and
other persons using any facility or system that FINRA operates or controls. FINRA further
believes that the proposed rule change is consistent with the provisions of Section 15A(b)(6) of
the Act,20 which requires, among other things, that FINRA rules are not designed to permit unfair
discrimination between customers, issuers, brokers or dealers.
The proposed rule change maintains the same equitable and not unfairly discriminatory
allocation of fees adopted in the 2024 Fee Filing. The proposed rule change simply modifies the
implementation schedule of this equitable allocation of fees, resulting in savings to members and
users of FINRA services.21 As described below, the savings are equitable and nondiscriminatory
across members by size and business model.
B.

Self-Regulatory Organization’s Statement on Burden on Competition

FINRA does not believe that the proposed rule change will result in any burden on
competition that is not necessary or appropriate in furtherance of the purposes of the Act.
Economic Impact Assessment
FINRA has undertaken an economic impact assessment, as set forth below, to analyze the
regulatory need for the proposed rule change, its potential economic impacts—including

19

15 U.S.C. 78o-3(b)(5).

20

15 U.S.C 78o-3(b)(6).

21

Users can include retail and institutional customers, counterparties, issuers or any other
party that might directly or indirectly share the burden of these fees, where members may
share the savings with them.
12

anticipated costs, benefits, and distributional and competitive effects—relative to the current
baseline, and the alternatives FINRA considered in assessing how best to meet its regulatory
objectives.
Regulatory Need
Since the adoption of the 2024 Fee Filing, FINRA’s financial position has improved
materially relative to the projections underlying that filing. As a result of the 2025 strategic
realignment discussed above, FINRA’s expenses have been reduced, while operating revenues
are expected to increase due to higher trading activities, higher member revenues, and the impact
of the 2024 Fee Filing.
As discussed above, based on an analysis of funding sources, anticipated costs, and an
assessment of current and projected market activities, FINRA has determined that a modification
to the implementation schedule of the fee increases adopted in the 2024 Fee Filing is appropriate
at this time.
Economic Baseline
The baseline for this proposed rule change includes FINRA’s current and projected costs
and revenues, the implementation schedule of fee increases adopted in the 2024 Fee Filing as
modified by SR-FINRA-2025-007, and the direct and indirect allocation of those fees across
members, associated persons, third parties, and investors. The baseline also encompasses the
scope of activities conducted by FINRA to meet its mission and FINRA’s current financial
position.22
Economic Impact

22

Any additional fee changes would take into account the savings provided by this
proposed rule change.
13

The proposed rule change is designed to provide savings to FINRA members while
preserving FINRA’s ability to both maintain its reserve balance within levels targeted under the
Financial Guiding Principles and continue to meet its regulatory mission. By delaying the
implementation of fee increases, the proposed rule change would reduce the near-term fee
burden on members without significantly altering the long-term fee structure or the equitable
allocation of fees established in the 2024 Fee Filing.
FINRA’s economic analysis below measures member savings, savings rates and the
distribution of savings rates across members during the four-year transitional period (i.e., 20272030). As mentioned above, total industry savings over this period are anticipated to be
approximately $718 million, representing approximately 9% of total baseline revenue over the
same period. On a per-member basis, the median four-year savings amount is $5,199, reflecting
the fact that most FINRA members are small firms. The median four-year savings rate is 7.2%,
and the average four-year savings rate is 6.7%.
Savings vary across years. The highest savings rates are in 2028, followed by 2029,
2027, and 2030, which has the lowest savings rate. This reflects the structure of the two-year
delay in the phase-in schedule.
Median Savings Rates By Category in Each
Year
2027
2028
2029
2030
By Firm Size
Large
Medium
Small

5.56%
6.13%
5.88%

14.12%
14.45%
14.18%

8.43%
8.28%
8.33%

3.34%
2.62%
2.68%

Micro
By Firm Business Model

2.07%

8.99%

6.01%

3.08%

Capital Markets and
Investment Banking
Clearing and Carrying

3.69%

11.93%

7.59%

2.94%

6.85%

14.85%

7.68%

2.30%

14

Diversified
Retail
Trading and Execution

6.84%
3.37%
5.86%

14.51%
11.61%
13.30%

7.84%
7.27%
7.56%

2.21%
3.50%
2.05%

To better understand the distribution of savings across members, FINRA analyzed the
dispersion of four-year savings rates around the median for all members and for groupings
defined by firm size and business model.
Number of
Members
in Category
3,193

All
By Firm Size
Large
153
Medium
202
Small
1,353
Micro
1,485
By Firm Business
Model
Capital Markets and
1,377
Investment Banking
Clearing and Carrying
138
Diversified
159
Retail
1,092
Trading and Execution
427
*SD = Standard Deviation

Median
Savings
Rate
7.2%

% of Members
Within One
SD* of Median
68.9%

% of Members
Within Two
SD* of Median
93.7%

8.2%
8.0%
8.0%
5.6%

72.5%
77.3%
78.9%
66.3%

96.1%
94.1%
92.9%
97.0%

7.1%

69.3%

93.5%

8.2%
8.0%
6.8%
7.5%

75.4%
72.4%
69.8%
71.5%

94.2%
93.8%
93.1%
94.0%

As the table shows, approximately 69% of all members fall within one standard
deviation, plus or minus, of the median savings rate (the central savings band). Approximately
94% of all members fall within two standard deviations. The dispersion of savings rates is
similar across all firm size categories and business models.

15

Charts 1 through 10 provide additional detail on the dispersion of four-year savings rates
by firm size, business model, and overall. 23 In each case, the proposed rule change limits the
number of members that fall beyond two standard deviations from the median in either direction.
In particular, the proposed rule change limits the number of members that would be expected to
experience a materially higher savings rate than the median (as defined by two standard
deviations). For the entire population of members, FINRA estimates that 0.2% would experience
savings greater than two standard deviations from the median savings.
Taken together, these results indicate that the proposed rule change provides savings that
are equitably distributed across the membership, maintaining a similar proportional allocation of
fees across firm sizes and business models established in the 2024 Fee Filing.
FINRA does not anticipate that the proposed rule change will materially impact
competition among members or between members and other providers of financial services. The
proposed rule change is a one-time delay, maintaining the same long-term allocation of fees
adopted in the 2024 Fee Filing. To the extent that the proposed rule change reduces the nearterm cost burden on members, it may modestly benefit members relative to non-FINRAregulated providers of financial services; however, FINRA does not believe this effect is
material, as the fee delay does not alter the fundamental regulatory framework or the relative cost
structure of FINRA membership.
Alternatives Considered
In developing this proposal, FINRA considered alternatives to the proposed two-year
delay.

23

Charts 1 through 10 are contained in Exhibit 3, available on FINRA’s website. See File
No. SR-FINRA-2026-020 (Form 19b-4, Exhibit 3) (available on FINRA’s website at
http://www.finra.org.
16

FINRA considered permanently reducing or eliminating certain of the fee increases
adopted in the 2024 Fee Filing rather than delaying them, but did not pursue this approach
because doing so could impair sustainable funding if key assumptions underlying FINRA’s
financial projections change materially.
FINRA also considered continuing to address revenue surpluses solely by issuing
additional rebates rather than modifying the fee increase implementation schedule. FINRA
determined that the proposed schedule modification is appropriate, as it provides members with
greater certainty and predictability in their budgeting and planning processes than retrospective
rebates.24
C.

Self-Regulatory Organization’s Statement on Comments on the Proposed Rule
Change Received from Members, Participants, or Others

Written comments were neither solicited nor received.
III.

Date of Effectiveness of the Proposed Rule Change and Timing for Commission Action
The foregoing rule change has become effective pursuant to Section 19(b)(3)(A)

of the Act25 and paragraph (f)(2) of Rule 19b-4 thereunder.26 At any time within 60 days of the
filing of the proposed rule change, the Commission summarily may temporarily suspend such
rule change if it appears to the Commission that such action is necessary or appropriate in the
public interest, for the protection of investors, or otherwise in furtherance of the purposes of the
Act. If the Commission takes such action, the Commission shall institute proceedings to
determine whether the proposed rule should be approved or disapproved.

24

As noted, FINRA is prepared to further address revenue surpluses in 2026.

25

15 U.S.C. 78s(b)(3)(A).

26

17 CFR 240.19b-4(f)(2).
17

IV.

Solicitation of Comments
Interested persons are invited to submit written data, views and arguments concerning the

foregoing, including whether the proposed rule change is consistent with the Act. Comments
may be submitted by any of the following methods:
Electronic Comments:
•

Use the Commission’s Internet comment form
(http://www.sec.gov/rules/sro.shtml); or

•

Send an e-mail to rule-comments@sec.gov. Please include File Number SRFINRA-2026-020 on the subject line.

Paper Comments:
•

Send paper comments in triplicate to Secretary, Securities and Exchange
Commission, 100 F Street, NE, Washington, DC 20549-1090.

All submissions should refer to File Number SR-FINRA-2026-020. This file number should be
included on the subject line if e-mail is used. To help the Commission process and review your
comments more efficiently, please use only one method. The Commission will post all
comments on the Commission’s Internet website (http://www.sec.gov/rules/sro.shtml). Copies
of the filing will be available for inspection and copying at the principal office of FINRA. Do
not include personal identifiable information in submissions; you should submit only information
that you wish to make available publicly. We may redact in part or withhold entirely from

18

publication submitted material that is obscene or subject to copyright protection. All
submissions should refer to File Number SR-FINRA-2026-020 and should be submitted on or
before [insert date 21 days from publication in the Federal Register].
For the Commission, by the Division of Trading and Markets, pursuant to delegated
authority.27

Sherry R. Haywood,
Assistant Secretary.

27

17 CFR 200.30-3(a)(12).
19

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Asec%3A2cad075cfa4d398e. Public record. Not legal advice.