We Strive to Foster a Culture of Transparency & Integrity

The Cost of Regulatory Recidivism: Why Independent AML Testing Matters

• A recent FINRA enforcement action resulting in a $20 million fine underscores the cost of persistent anti-money laundering (AML) failures. FINRA's use of "progressive discipline" in the case signals a diminishing tolerance for firms that fail to remediate known compliance gaps, particularly those involving foreign currency wires and customer due diligence (CDD).

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Client Success Story: Independent AML Testing

• At Diles Consulting, we take pride in delivering compliance solutions that are practical, professional, and tailored to each client's unique needs. We are honored to share feedback from a recent Independent AML Testing client that plans to engage us in 2027. The CEO "... thought the engagement with Diles was very professional and demonstrated a quick and clear understanding of how our business functions. The advice offered was constructive and rational."

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Testimonials

• "Colleen was incredibly flexible with her time, easy to work with, and someone I could consistently rely on to help me get things done. On top of that, she's a great teacher—she has a real gift for breaking down the fine points in a way that’s easy to understand, especially when things get a bit technical..."

Testimonials

Understanding When a Continuing Membership Application Is Required

• FINRA member firms are subject to ongoing obligations under NASD Rule 1017 to notify FINRA of material changes in business operations through a Continuing Membership Application (CMA). Firms that undergo qualifying changes without filing a CMA may be found in violation of their membership terms during a routine examination.

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Navigating the Membership Process: Strategic NMA Support from Diles Consulting

• Entering the financial services sector requires navigating the complexities of a FINRA New Member Application (NMA), a task that can be a significant hurdle for new firms.

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Expert Witness - Areas of Expertise

• FINRA Programs
• FINRA Risk Hierarchy
• FINRA Sales Practice Issues
• FINRA and SEC Rules
• Assessment of Internal Controls
• Broker-Dealer Compliance and Supervision
• Broker-Dealer Regulatory Issues
• Risk Monitoring and Mitigation

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Colleen Diles to Moderate SER 2026 Panel as Diles Consulting Sponsors Annual Conference

• Diles Consulting is proud to announce its sponsorship of the Securities Experts Roundtable (SER) 2026 Annual Member Meeting and Conference, taking place August 6–7 at the Sofitel Hotel in Washington, D.C.

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Diles Consulting Celebrates Another Successful FINRA Membership Approval

• Diles Consulting is pleased to share that another client has recently obtained FINRA membership approval. Our company provided comprehensive support to this client during the New Membership Application (NMA) process, from initial filing through the welcome letter, offering guidance along the way.

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FINRA Amends Rule 1210: Reduced Exam Retake Waiting Periods for Broker-Dealers

• FINRA has filed a proposed rule change to amend Rule 1210 (Registration Requirements) to shorten the mandatory waiting periods for individuals retaking failed qualification examinations.

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Navigating Regulatory Harmony with Expert Compliance Solutions from Diles Consulting

• The SEC and NFA have established a Memorandum of Understanding (MOU) intended to facilitate the sharing of information regarding emerging risks, examination planning, and financial market conditions. While the agencies suggest this coordination will minimize duplicative oversight and provide a more predictable ...

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FINRA's Proposed Rule 2210 Amendment: What Firms Need to Know About Performance Projection Communications

• The Securities and Exchange Commission (SEC) recently issued an order instituting proceedings to determine whether to approve a proposed amendment to FINRA Rule 2210 (Communications with the Public). Currently, Rule 2210 generally prohibits member firms from predicting or projecting performance in public communications.

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Navigating FINRA's Shifting Regulatory Proposals: Strategic Compliance Solutions from Diles Consulting

• During its June meeting, the FINRA Board of Governors approved its 2025 Annual Financial Report alongside four rule proposals that the regulator characterizes as part of its "FINRA Forward" modernization initiative. While FINRA asserts that these measures are intended to "reduce unnecessary regulatory burdens," the proposals remain subject to further SEC oversight and filing.

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Navigating "FINRA Forward" with Expert Compliance Solutions

• The securities industry continues to shift, and regulatory bodies along with compliance professionals are adjusting their approaches accordingly. The following overview describes the current regulatory landscape and the methodologies applied to complex compliance requirements.

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50/50 Women on Boards LA: Colleen Diles Volunteers at Board Leadership Conference Drawing 300+ Attendees

• Los Angeles Conversation on Board Leadership served as a premier gathering for aspiring board leaders and business executives. Held at the California Endowment in downtown Los Angeles, the event was exceptionally well attended, with over 300 people...

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FINRA Examination Program Alert: Broker-Dealer Supervision of Structured Products Under Rule 3110 and Reg BI

• In May, FINRA announced that it will review firm practices related to supervision of higher-risk structured products. Structured products are designed to meet specific investment objectives for retail investors, such as growth, income, or risk management. They typically combine a traditional security, like a bond, with a derivative component

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Navigating Broker-Dealer Regulatory Issues: Key Insights from the 2026 FINRA Examination Program and SEC Rules and Regulations

The 2026 FINRA Annual Regulatory Oversight Report provides broker-dealers with a comprehensive roadmap of current regulatory priorities and emerging risks. A significant highlight for this year is the introduction of GenAI: Continuing and Emerging Trends, reflecting FINRA's focus on how new technologies impact firm operations.

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FINRA's Evolving Examination Program: Transparency Enhancements

In a recent podcast, Senior Management discussed how FINRA is looking to evolve its examination program to be more risk-informed, efficient, and transparent. Their enhancements are aimed at reducing the regulatory burden on member firms while strengthening market integrity and investor protection. By leveraging new technology and internal data, FINRA intends to shift away from traditional, broad oversight toward a more targeted approach that focuses resources on the areas of greatest potential risk to investors.

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Expert Witness - Areas of Expertise

• FINRA Programs
• FINRA Risk Hierarchy
• FINRA Sales Practice Issues
• FINRA and SEC Rules
• Assessment of Internal Controls
• Broker-Dealer Compliance and Supervision
• Broker-Dealer Regulatory Issues
• Risk Monitoring and Mitigation

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Broker-Dealer Regulatory Issues: FINRA Gives CABs More Room to Work

Did you know FINRA has amended its Capital Acquisition Broker (CAB) rules, giving these specialized firms significantly greater flexibility in private markets? As of March 25, 2026, the amendments reflect FINRA's broader initiative to modernize its regulatory framework while keeping core investor protections firmly in place.

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Commitment to Service and Integrity

Diles Consulting is proud to have sponsored and attended the Florida Securities Dealers and Advisors Association (FSDA) Generational Day of Financial Literacy - Together for Financial Literacy: Protecting Families Across Generations inaugural event in Boca Raton, FL. This milestone event reflects our deep commitment to community service, financial literacy, and the belief that stronger, more informed communities are built one conversation at a time.

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Expert Insights: Colleen Diles on FINRA Compliance in Legent Group Case

In the recent Delaware Court of Chancery decision involving Legent Group and Axos Financial, industry expert Colleen Diles provided key testimony that shaped the court's understanding of regulatory compliance standards.

With over two decades of experience working in FINRA's Member Supervision Department, Diles explained that firms must establish a supervisory system that is reasonably...

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