Comment on FINRA Regulatory Notice 25-07: Modernizing FINRA Rules, Guidance, and Processes for the Organization and Operation of Member Workplaces
FINRA’s rule modernization effort was built around large-firm assumptions. TOBIN spelled out what that costs boutique firms: inspections triggered by routine marketing approvals, enforcement investigations with no defined endpoint, and informal guidance enforced retroactively. She pushed for codified rules, shorter exam cycles, and a framework that treats small firms as professionals, not suspects.