FINRA Conflicts for Own Staff

On Oct. 24, FINRA proposed rules on post-office staff conflicts.

  • To adopt Rule 9910 post-employment conflict restrictions; nonpublic information.

Ban Ex-Employee Advocacy

  • Prohibit former officers from communication or appearance at FINRA, for a year.
  • Any ex-employee banned from advocating FINRA at any time in matter involving
    specific party with whom personally or substantially involved during employment.
  • Ban on ex-employees from matters involving a specific party or parties, that was
    under the employee’s official responsibility during last year of FINRA employment.

Non-Public Information

  • Current employee ban on disseminating or disclosing, in purpose unnecessary to
    FINRA job responsibilities, any nonpublic information obtained from empoyment.
  • Also restrict ex-employee from disseminating or disclosing nonpublic information.
  • Unless disclosure expressly authorized by FINRA or required or protected by law.


  • Comment period is until 21 days from pending publication in the federal register.
  • FINRA filed proposed rule change for immediate effectiveness, after SEC review.
  • Operative date of para (b), (c) and (d) of FINRA Rule 9910 will be Dec. 3, 2018.
  • The operative date of paragraph (a) of proposed FINRA Rule 9910, Apr. 1, 2019.