“Extraordinary Cooperation” Credit FINRA | FTI Consulting

Chasing “Extraordinary Cooperation” Credit in FINRA Investigations

Action Alert

Forensic & Litigation Consulting

October 24, 2019

FINRA’s recently issued guidance on potentially qualifying actions during an investigation for “extraordinary cooperation” credit seeks to clarify what a member could do to earn a reduction in fines and/or sanctions. While any guidance is helpful, seasoned professionals know that for each successful application for such credit, there are several failed applications where members did all they could think of to cooperate but reaped no discernable discount in penalties or sanctions.

FTI Consulting’s Broker-Dealer Regulatory Practice can advise and assist in all phases of a FINRA investigation, from disclosure to scoping, correction and remediation. Our expertise and thorough documentation can be the tipping point in a successful bid for credit.

Our services can be scaled to align with any compliance strategy while providing flexibility to meet and exceed FINRA’s expectations. Our team of former in-house practitioners and former regulators have experienced insight in the following areas:

  • Correcting deficient procedures and systems
  • Quickly identifying impacted customers and providing restitution using data analytics tools
  • Assisting with investigations
  • Advising on the benefits of self-reporting potential violations

Our multidisciplinary approach combines our broker-dealer expertise with world-class investigations and data analytics practices to deliver the best possible outcome for a FINRA inquiry.


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