Compliance Corner: FINRA and SEC Updates - September 2025

Each month, our Compliance Corner brings you the most important regulatory updates, breaking down what changed, why it matters, and how it may affect your business.

Here is what you need to know from September 2025:

New FINRA Filing System Requirement

In Regulatory Notice 25-10 (Sept 17, 2025), FINRA announced that all disciplinary filings must now be submitted through the new Office of Hearing Officers (OHO) Docket Portal, effective October 7, 2025.

Why it matters:

The OHO is the body that adjudicates enforcement actions. This shift to a centralized online portal represents:

• Greater efficiency: One platform for all case documents.
  
  
• More transparency: Clear records of filings and deadlines.
  
  
• Reduced error risk: Eliminates inconsistent submission methods.
  
  

Even if your firm doesn’t anticipate OHO proceedings, this marks FINRA’s broader shift to digital-first compliance infrastructure—a trend we expect to accelerate.

Updates to Trade Reporting Requirements

Rule Filing SR-FINRA-2025-012 proposes amendments to Rule 6860 (Time Stamps) regarding the Consolidated Audit Trail (CAT). This would revise the expiration of an exemption related to timestamp granularity.

Why it matters:

The CAT is the backbone of U.S. trade surveillance. Timestamps help regulators detect manipulation and reconstruct activity with precision.

Firms should:

• Check system readiness: Ensure OMS/EMS platforms are compliant.
  
  
• Review vendor capabilities: Confirm your vendors can meet the new specs.
  
  
• Expect tighter standards: FINRA is doubling down on data integrity and auditability.
  
  

This isn't just technical—it reflects growing scrutiny on reporting accuracy across capital markets.

FINRA’s Push into Digital Assets Education

On September 16, FINRA launched a Crypto and Blockchain Education Program, in partnership with Georgetown University’s McDonough School of Business. The initiative includes online modules and in-person sessions beginning in October.

Why it matters:

Even if your firm doesn’t currently deal in digital assets, this investment signals that crypto and blockchain are now front and center in the regulatory agenda.

Prepare for:

• More guidance and best practices.
  
  
• Dedicated exams and audit criteria.
  
  
• Potential new compliance obligations around digital assets.
  
  

Get Involved: FINRA Governance Elections

On September 4, FINRA issued two Election Notices:

• Call for candidates for Regional Committees
  
  
• Call for candidates for the Small Firm Advisory Committee (SFAC)
  
  

Why it matters:

Participation in FINRA governance is a powerful way for member firms to shape future regulations. If your team wants a seat at the table, this is your chance to influence compliance policy directly.

Key Takeaways for September

• Digital-first compliance is here. Get familiar with the OHO Docket Portal before October.
  
  
• CAT reporting standards are tightening. Audit your timestamp precision now.
  
  
• Crypto education is rising. Stay ready for evolving obligations.
  
  
• Engagement matters. Consider contributing to FINRA governance structures.
  
  

Frequently Asked Questions

What is FINRA's OHO Docket Portal?
The OHO Docket Portal is a centralized online system for submitting filings in disciplinary cases—aimed at improving efficiency and reducing errors.

How do CAT timestamp changes impact broker-dealers?
They require systems to capture more granular time data, improving surveillance and audit readiness.

Why is FINRA investing in crypto education?
To prepare the industry for the growing relevance and complexity of digital assets in regulated markets.

How can my firm participate in FINRA elections?
Review the current Election Notices on FINRA’s site and consider nominating qualified representatives.

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