In April 2020, the Financial Industry Regulatory Authority and nearly all of the national securities exchanges announced they had formed a Cross-Market Regulation Working Group (CMRWG) to share information and reduce unnecessary duplication in the participants’ regulatory efforts.

This development comes at a time when the exchanges are increasingly expanding their role in conducting enforcement investigations and prosecuting enforcement matters. Although FINRA and the exchanges currently coordinate and effectively centralize most enforcement investigations, recent changes indicate a move toward a more decentralized model and the possibility that exchanges may independently bring significant disciplinary cases against brokers.

Originally published in Bloomberg Law - August 2020.