CSG Law Alert: FINRA’s 2025 Enforcement Statistics Reveal a Surprising Trend
Overall, FINRA’s 2025 disciplinary statistics reflect a significant reining-in of FINRA’s enforcement program. As compared to 2024, FINRA filed 127 fewer formal disciplinary actions,1 a drop-off of about 23%. FINRA also ordered substantially less restitution to be paid to harmed investors, specifically, approximately $14.3 million in 2025 versus $24 million in 2024. However, one FINRA constituency seemingly has been left out of this “kinder and gentler” approach to enforcement—small firms.
Indeed, in 2025, FINRA filed 103 formal disciplinary actions against small firms, a 27% increase from 2024.2 At the same time, the number of formal disciplinary actions filed against large firms dropped by more than 30%. Perhaps more troubling for small firms, this increase appears to be part of a larger pattern. 2025 marks the fourth year in a row that FINRA has increased, year over year, the number of formal actions filed against small firms. In fact, since 2020, the number of formal disciplinary actions FINRA filed against small firms increased more than 90%, while the number of formal disciplinary actions filed against large firms decreased roughly 32% during this same period.
While one can debate whether these statistics reflect a concerted effort by FINRA to target small firms, one thing is for sure—small firms should be aware of this trend and prepared to defend themselves vigorously against FINRA in the new year.
1 Our use of the term “disciplinary actions” refers to filed settlements and complaints.
2 FINRA separates its member firms into three categories—small, mid-size, and large—based on the firms’ population of representatives: small firms = 1-150 representatives; mid-size firms = 151-499 representatives; and large firms = 500 or more representatives.