Last month, Sutherland Asbill & Brennan published data revealing FINRA’s first-half fine total for 2015.  The good news: FINRA’s $37.5 million in first-half 2015 fines is down from $42.4 million for the same time period last year.  Projected for the full year, a total of $75 million for 2015 fines imposed by FinesFINRA would be a 44% drop from the total fines that FINRA reported in 2014 ($135 million). The bad news: the projected $75 million in fines would still be a banner year for FINRA, as it would be the second-highest amount of fines imposed by the regulator since the financial crisis.

Sutherland’s report also noted the “Top Enforcement Issues” for FINRA for the first-half of 2015, which was aggregated from fines reported in FINRA’s monthly Disciplinary and Other FINRA Actions reports and News Releases:

  1. Trade Reporting: $7.6 million in fines (72 cases);
  2. Short Selling: $4.2 million in fines (21 cases);
  3. Anti-Money Laundering: $2.4 million in fines (20 cases);
  4. Best Execution: $2.3 million in fines (25 cases); and
  5. Suitability: $2.2 million in fines (30 cases).

While the drop in fines to start the year is certainly a welcome sight, FINRA is clearly still very active in imposing fines.  Firms should continue to closely monitor their policies and compliance, particularly in the above areas.  Brian L. Rubin, head of Sutherland’s Washington litigation practice group, suggested that, to avoid FINRA sanctions, “firms should continue to focus on nuts and bolts issues, such as disclosure, suitability, AML and trade execution.”