FINRA Delays Scheduled Fee Increases by Two Years, Holding 2026 Rates Through 2028

Key Takeaways

• FINRA filed SR-FINRA-2026-020 for immediate effectiveness, postponing all remaining fee increases adopted in the 2024 Fee Filing by two years.
• Members will pay 2026 rates from 2027 through 2028, with a median savings rate of 7.2% and approximately USD $718 Million in aggregate savings over 2027 to 2030.
• Compliance and finance teams should update budgets, fee pass-through disclosures, and forecasts now.

Deep Dive

FINRA filed SR-FINRA-2026-020 for immediate effectiveness, postponing all remaining fee increases adopted in the 2024 Fee Filing by two years. Members will pay 2026 rates from 2027 through 2028, with a median savings rate of 7.2% and approximately USD $718 Million in aggregate savings over 2027 to 2030. Compliance and finance teams should update budgets, fee pass-through disclosures, and forecasts now.

The filing modifies the implementation schedule set in SR-FINRA-2024-019, as modified by SR-FINRA-2025-007. It is effective on the date of filing. FINRA cites revenues running well above projections (higher trading volumes, higher member revenues, and the 2024 fee increases) and a 10% budgeted expense reduction for fiscal 2026 following its 2025 strategic realignment. It rebated USD $100 Million of 2025 fees in March 2026 and USD $50 Million of 2024 fees in 2025. FINRA projects that implementing the remaining increases as scheduled would push reserves above the target under its Financial Guiding Principles, which is at least one year of expenditures.

The new schedule moves the 2027 fee changes to January 1, 2029, the 2028 changes to January 1, 2030, and the 2029 changes to January 1, 2031. Affected fees include the Gross Income Assessment, Trading Activity Fee, Personnel Assessment, Branch Office System Processing Fee, Registration Fees (Form U4, Form U5, disclosure review, fingerprinting), Renewal Late Fee, System Processing Fee, and the Corporate Financing Private Placement and Public Offering Review Fees. The Corporate Financing fees, previously set for January 1, 2027, now begin January 1, 2029. Examples of 2029 and later changes: the Trading Activity Fee for covered equities rises from USD $0.000195 to USD $0.000232 per share, and the non-WKSI public offering fee cap rises from USD $225,000 to USD $1,125,000. Fees already fully implemented in 2025 or 2026 (such as Advertising Regulation Review, Continuing Education Regulatory Element, and Qualification Examination fees) are unaffected. The change applies to all members, including funding portals and capital acquisition brokers. By 2031, rates converge with the 2024 schedule, so the savings are a timing benefit over the 2027 to 2030 transitional period only. FINRA reports total savings of approximately 9% of baseline revenue over that period, and a median per-member savings of USD $5,199.

Recommended actions: revise 2027 and 2028 regulatory fee budgets to hold at 2026 rates, and reset multi-year forecasts to reflect the 2029 to 2031 step-ups. Review customer-facing pass-through practices for the Trading Activity Fee, since the filing notes that members may share savings with customers, and confirm that disclosures and fee schedules remain accurate. Corporate finance and capital markets teams should update issuer fee expectations, and should monitor the SEC's proposed elimination of the WKSI definition, which could lead FINRA to revisit the offering fee structure. Also note that FINRA says future fee changes would account for these savings, and it may file separate fees for new services.

Risk implications are low and mostly financial. The main uncertainty is that the SEC may suspend an immediately effective filing, and FINRA says it could further adjust through rebates or fee reductions if assumptions change. Firms should avoid treating the deferral as permanent relief, given the steeper 2029 to 2031 increases and the possibility of further changes.

Source: Financial Industry Regulatory Authority