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Regulatory Notice 26-12

Summary

In November 2025, Securities and Exchange Commission (SEC) staff issued a no-action letter permitting registered representative-owned personal services entities to receive transaction-based compensation without broker-dealer registration, subject to conditions. This Notice provides guidance regarding the manner in which FINRA rules apply in relation to the no-action letter. This Notice does not apply new requirements beyond the no-action letter requirements.

2025088238401 Tiffany L. Felker CRD 8016078 AWC ks.pdf

Between December 2024 and January 2026, Felker willfully failed to disclose on her Uniform Application for Securities Industry Registration or Transfer (Form U4) that she had been discharged from a former employer following allegations that she violated investment-related rules and industry standards of conduct. Felker also signed an initial Form U4 and a Form U4 amendment in which she falsely stated that she had not been discharged from a former employer following such allegations.

2023077078301 TradingBlock CRD 128605 AWC ks.pdf

From December 2018 to the present, TradingBlock failed to establish and implement an anti-money laundering (AML) compliance program reasonably designed to detect and cause the reporting of suspicious transactions. The firm also failed to include in its AML program appropriate risk-based procedures for conducting ongoing customer due diligence and monitoring. As a result, the firm violated FINRA Rules 3310(a), 3310(f), and 2010. For these violations, TradingBlock consented to a censure, a $210,000 fine, and an undertaking to certify that it has remediated its AML policies and procedures.
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