FINRA Provides Guidance On Enforcement Credit For "Extraordinary Cooperation"

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Cadwalader, Wickersham & Taft LLP

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FINRA provided guidance on enforcement credit for firms or individuals that provide "extraordinary cooperation" in investigations.
United States Finance and Banking
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FINRA provided guidance on enforcement credit for firms or individuals that provide "extraordinary cooperation" in investigations.

In a regulatory notice, FINRA clarified that it incentivizes firms and individuals to comply with investigations by crediting "extraordinary cooperation" that exceeds FINRA rule requirements. FINRA defines "extraordinary cooperation" as including (i) the self-reporting of violations, (ii) taking early and vigorous steps to correct problems, and (iii) making substantial and immediate remediation to customers or (iv) providing a significant amount of assistance to FINRA's investigation, including cooperating with FINRA to "uncover substantial industry wrongdoing."

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