Compliance & Ethics

FINRA has reissued a reminder about NSCC's requirement for firms to establish separate 9A/9B trading relationships to support overnight trade clearing under the industry's 24x5 trading initiative. While FINRA itself is not mandating changes to Uniform Reporting Agreements, firms that fail to meet NSCC's requirements risk having overnight trades accepted at the TRF but rejected at NSCC, creating a trade break and operational/settlement risk.

FINRA has finalized two significant rule changes—a streamlined Outside Activities rule and a new intraday margin framework eliminating the Pattern Day Trader designation—as part of its FINRA Forward modernization initiative. Compliance teams must update policies, procedures, and training to reflect these changes while monitoring a pipeline of additional pending proposals covering senior investor protections, e-delivery defaults, remote inspections, and AI-related supervisory standards.

The Federal Commissioner for Data Protection and Freedom of Information (BfDI) issued a statement on Germany's draft law implementing EU Regulation (EU) 2025/327 (EHDS Regulation) for healthcare data and digital innovation. The statement generally endorses the government's draft while providing detailed technical feedback on proposed amendments concerning access logging, document-level access controls in electronic patient records, research data linkability, and consent-based data processing authorization requirements. Healthcare organizations and health insurers operating in Germany should monitor this legislation closely as it will materially affect data governance obligations under both national law (SGB V, GDNG-E) and the EHDS framework.

The European Banking Authority has published a user guide explaining the conversion file that maps old DPM 1.0 glossary elements to the new DPM 2.0 glossary structure, resulting from its ongoing Quality Review project. Compliance and reporting teams must understand this mapping as it underpins the modeling of all EBA reporting frameworks and will inform the upcoming v4.0 release, directly affecting regulatory reporting taxonomies.

De Nederlandsche Bank (DNB) will hold a physical, Dutch-language information session on 5 November 2026 to explain its fit and proper assessment process for board members and key function holders. Compliance teams at supervised institutions should encourage affected candidates and HR/legal staff to register by 2 November to gain direct insight into assessment expectations and recent regulatory developments.

The AMF's 2025 annual data collection from 6,713 Financial Investment Advisors (CIFs) reveals growing market polarization, with the top 50 firms now capturing 52% of sector revenue, up from 49% in 2024. Compliance teams at affected firms and their professional associations should note the shifting revenue concentration, persistent fee-based compensation structures, and the continued marginal role of crypto-assets in CIF advisory activity.

The FCA has added "Hope Fund Bank" (hopefundbank.com) to its Warning List for providing or promoting financial services in the UK without authorization. Compliance teams should note this entity for screening purposes, as consumers dealing with it have no access to the Financial Ombudsman Service or FSCS protection.