Finalis Weighs In on FINRA’s Rulebook Overhaul, Advocating for Modernization in Private Markets

In a strong show of leadership, Finalis Securities, LLC submitted a public comment in response to FINRA’s Regulatory Notice 25-04, which solicits industry feedback on a comprehensive modernization of its rules. 

Representing a network of over 500 affiliated professionals and more than $90 billion in active deal volume, Finalis offered a perspective shaped by deep insight into how investment banking is evolving in the digital era.**

A Firm Rooted in Compliance and Innovation

Finalis’ letter underscores its commitment to operating in full compliance with SEC and FINRA regulations. Yet, as a tech-enabled platform supporting private placements and M&A advisory across a distributed, predominantly virtual network of registered representatives, the firm also highlighted the need for FINRA to adapt its regulatory frameworks to align with modern operating models.

Specifically, Finalis detailed how it integrates modern digital workflows, secure cloud-based systems, and AI-driven compliance tools to enhance supervisory controls and streamline deal execution. The letter articulates the challenges of maintaining effective supervision within decentralized work environments, a reality increasingly common among broker-dealers post-COVID.

Key Themes in Finalis’ Commentary

Finalis focused on several areas of critical importance to its model and to the industry at large:

• Redefining the term “branch office” and reconsidering related supervisory rules
• Balancing the risks and benefits in the adoption of AI
• Modernizing rules to reflect the expanded digital footprints of registered representatives and addressing the challenges of effective supervision in the digital era
• Supervising brokerage accounts for firms, like Finalis, that primarily conduct business in private placements and M&A transactions

These inputs reflect Finalis’ vision: reducing structural barriers in capital formation and improving transaction integrity, without compromising on investor security.

A Broader Call for Practical Reform

Rather than calling for blanket deregulation, Finalis is advocating for nuance. It is important to recognize that different firm types require differentiated oversight models. 

Finalis invites FINRA to consider more scalable and flexible approaches to supervision, particularly for low-risk, advisory-focused firms operating outside the traditional retail framework.

Any modernization initiative should preserve core investor protections, while enabling firms to adopt innovative, risk-sensitive compliance practices that align with the realities of modern dealmaking.

Finalis’ engagement in this dialogue with FINRA reflects more than regulatory housekeeping, it signals the maturation of digital-first infrastructure in private capital markets. As modern platforms like Finalis reshape how deals are sourced, supervised, and executed, their voices are crucial in shaping a regulatory future that works for both compliance and innovation.

Learn more about Finalis’ commitment to regulatory leadership and next-gen deal infrastructure at www.finalis.com.