Report

SEC and FINRA Enforcement Trends for Broker-Dealers: 2025-2026

A forward-looking analysis of SEC and FINRA priorities, enforcement shifts, and exam trends shaping broker-dealer compliance and litigation risk for 2026 and beyond.

March 2026

Authors: Ariel Gursky, Ben A. Indek, Carolyn M. Welshhans, Griffin J. Abbott, Aidan M. Delaney, Elisabeth Grippando

In 2025, the US Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) experienced significant leadership changes, staffing departures, and a renewed “back to basics” emphasis on traditional retail investor fraud. This report analyzes key enforcement and examination developments affecting broker-dealers, explains what changed in 2025—including limited public enforcement metrics—and outlines what firms should anticipate from SEC and FINRA oversight in 2026 and beyond.

Key Takeaways

Division of Enforcement activity declined in 2025 amid leadership transitions and significant staffing reductions.
Divisions of Enforcement and Examinations interest in large broker-dealers will continue, particularly for “sweep-like” matters that focus on a particular practice or conduct affecting a number of firms.
Retail investor protection remains the dominant enforcement focus for both the SEC and FINRA.
Regulation Best Interest, best execution, anti-money laundering, and trading practices remain core broker-dealer risk areas.
Cybersecurity enforcement is intensifying, particularly around account takeovers and Regulation S-P compliance.
FINRA Forward and AI oversight are reshaping supervision and enforcement expectations.

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What’s Inside the Report

This report provides practical insight into how broker-dealers can prepare for evolving SEC and FINRA oversight, including:

Shifts in SEC enforcement mix and broker-dealer case trends
Remedies and penalty considerations (including disgorgement, restitution, cooperation credit, and independent compliance consultants)
SEC rulemaking changes affecting broker-dealers (including withdrawn proposals and continuing requirements)
2026 SEC exam priorities and likely referral patterns
FINRA Forward initiatives and what they mean for enforcement posture
FINRA enforcement focus areas and how the program is changing
FINRA’s use of artificial intelligence (AI) and generative AI oversight themes in the 2026 Annual Regulatory Oversight Report