Regulatory Outlook: Key FINRA and SEC Developments – September 2025

Regulatory Outlook: Key FINRA and SEC Developments – September 2025

FINRA Moves to Modernize Pattern Day Trading Rules

At its September 17–18 meeting, the FINRA Board of Governors approved amendments that will replace the long-standing pattern day trading rule including the $25,000 minimum equity requirement, with a new intraday margin standard.

This change applies maintenance margin principles to intraday exposure, aligning oversight with today’s fast-moving, technology-driven trading environment. The proposal follows a retrospective review and feedback from firms and investors.

Why this matters:

  • Reduces rigidity in the $25,000 threshold for active traders.
  • Aligns capital requirements with real-time exposure.
  • Reflects FINRA’s broader shift toward modern, risk-based oversight.

The amendments will be filed with the SEC for approval. Firms should prepare for system updates to monitor intraday margin calculations once finalized.

FINRA Forward Initiative Accelerates Rule Modernization

As part of its ongoing FINRA Forward initiative, the Board approved several proposals designed to simplify compliance while supporting capital formation and investor protection. Key updates include:

  • Corporate Financing Rules: Streamlined requirements to facilitate efficient fundraising.
  • Outside Activities: Clarified requirements for associated persons engaging in external business.
  • Gift Limit Increase: The allowable value rises from $250 to $300, reflecting cost-of-living adjustments.
  • Capital Acquisition Broker (CAB) Rules: CABs may now represent both buyers and sellers in select private placement and M&A transactions.

FINRA also plans to issue a Regulatory Notice consolidating guidance on the use of negative consent for bulk account transfers, reducing duplicative procedures for member firms.

Why this matters:
The FINRA Forward initiative continues to reshape how firms interact with regulation. The focus is on clarity, consistency, and enabling compliant growth.

Cybersecurity and Market Surveillance Remain Core Priorities

The Board received updates on FINRA’s cybersecurity strategy and ongoing developments with the Consolidated Audit Trail (CAT). Both programs remain central to market integrity and oversight.

Key points:

  • FINRA reaffirmed its focus on protecting sensitive market data.
  • CAT continues to evolve as the foundation for trade surveillance and audit reconstruction.
  • Firms should expect ongoing scrutiny of timestamp precision and data reporting accuracy.

Why this matters:
Data integrity and cybersecurity readiness are no longer optional. Member firms should conduct system reviews and internal audits to ensure compliance with FINRA’s evolving standards.

Reaffirmation of Financial Guiding Principles

FINRA reaffirmed its Financial Guiding Principles, which outline how the organization manages its financial resources with transparency and accountability. The reaffirmation underscores FINRA’s commitment to responsible governance and fiscal discipline.

Key Takeaways for September 2025

  • Pattern Day Trading Rules Revised: A new intraday margin model will replace the traditional $25,000 equity requirement.
  • Regulatory Modernization Accelerates: FINRA Forward continues to update key rules across corporate financing, gifts, and CAB frameworks.
  • Cybersecurity Oversight Expands: Expect heightened focus on CAT data integrity and cyber risk management.
  • Commitment to Transparency: FINRA reinforces financial stewardship through its guiding principles.

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