The National Adjudicatory Council issues a decision on an appeal. Who serves it on the parties?

The Office of Hearing Officers, which serves every document any Adjudicator issues

The Council itself; each body outside that office serves what it issues

The Department of Enforcement, which serves on behalf of whichever body decided

Whichever body issued the decision under review, the record remaining with it

A respondent does not check the Portal for several weeks and misses a scheduling order, then says they never saw it. What follows?

The period runs afresh from the date they are shown actually to have seen it

The office must serve the order again by a method producing confirmed receipt

Nothing; service was complete on submission and watching the Portal is theirs to do

The Hearing Officer decides whether the failure was reasonable in the circumstances

Outside the Office of Hearing Officers, electronic mail became available in 2022 for serving an Adjudicator's orders and decisions. What did it become?

One authorised method among the traditional ones, which remain available

Available only where a party has asked in writing to be served that way

The mandatory default, the traditional methods ceasing to be available for such documents

The method for procedural orders, decisions continuing to go by traditional means

A default decision is entered against a respondent who never answered. Why is it served by traditional methods rather than through the Portal?

Because a decision is a more formal document than an order and warrants a formal method

Because someone who never engaged may have no Portal access to be served through

Because the Portal records service only where the party has previously used it

Because a defaulting respondent's Portal access is suspended once default is entered

A Hearing Officer presiding over a Rule 9200 series disciplinary proceeding issues an order ruling on a discovery motion. Where does responsibility for serving that order on the parties rest?

With the party whose motion the order decided, which then serves it on every other party

With the Hearing Officer personally, as the Adjudicator whose signature the order carries

With the Office of Hearing Officers as a body, rather than the officer who signed it

With the Department of Enforcement, as the party that brought the proceeding against the respondent

Counsel for a respondent has filed a notice of appearance. An Adjudicator's order is then served on counsel alone, nothing going to the respondent, and no order requiring direct service has been made. How does service on the respondent stand?

Incomplete until the respondent has signed an acknowledgment of the order's receipt

Incomplete, since an Adjudicator's orders must reach the party personally as well as counsel

Complete only once counsel confirms that the order has been passed on to the respondent

Complete, since service on counsel satisfies the obligation owed to that party

In a Rule 9200 series proceeding, a Hearing Panel wants one particular order to reach a respondent who is taking part in a way that verifies actual receipt. What may the Panel do?

Order that the document be served by a method other than the Portal

Nothing more, the Portal having to be used for every order issued in the case

Direct the Department of Enforcement to serve it on the Panel's behalf by courier

Treat it as a default document, so that the default carve-out sends it by mail

In a disciplinary proceeding, a respondent disputes the date on which an order was served on it through the OHO Portal. What settles when service occurred?

The time the respondent first opened the order, as the Portal's access history shows

The submission time the Portal records automatically in its audit system

The date the order bears on its face, which is treated as its date of service

A sworn statement by the staff member who uploaded it, filed with the order

Under the Portal system, how is the case record of a Rule 9200 series disciplinary proceeding kept?

As two records, the parties' filings in the Portal and the Adjudicator's rulings in a separate file

As a physical file at the Office of Hearing Officers' premises, the Portal serving to deliver copies

As one electronic record holding orders and party filings alike, open to every party with Portal access

As an electronic record that shows each party the documents it filed or was served, and no others

A respondent fails to answer a complaint. A second notice requiring an answer follows, and later a default decision; both go by personal service, mail or courier. Why does the rule on serving Adjudicator-issued documents govern only the decision?

The notice comes before default is entered, so the default carve-out does not yet reach it

The notice is issued by the Office of Hearing Officers administratively, not by an Adjudicator

The rule reaches rulings that decide something, and a notice demanding an answer decides nothing

The notice is issued by the Department of Enforcement as a party, not by an Adjudicator

The National Adjudicatory Council e-mails an order to an unrepresented respondent on a Monday. The respondent is travelling and first opens the message nine days later. When was the order served?

On the Monday, service by electronic mail being complete when the order is sent

Nine days later, when the respondent first opened the message and could read it

On the Tuesday, e-mail service taking effect on the business day after sending

When the respondent replies to acknowledge it, the acknowledgment being what establishes receipt of e-mail

The National Adjudicatory Council sends its appeal decision to an unrepresented respondent through a courier service that generates written confirmation of receipt. Has it used a method the rule on serving Adjudicator-issued documents allows?

No; the Council must use personal service, mail or e-mail, courier being unavailable to it

Yes; courier is among the Rule 9134 methods open to it, with personal service and mail

No; courier may be used only after an attempt at personal service has failed

Yes, but because the respondent agreed in advance to accept service of the decision by courier

A respondent's attorney has filed a notice of appearance in an appeal. The National Adjudicatory Council e-mails its decision to the respondent's own address and sends nothing to the attorney. How does service stand?

It is valid, the e-mail address the respondent gave in its first filing being its address for service

It is valid; the respondent is the person whose rights the decision determines, so serving the respondent suffices

It falls short; with an appearance on file, the decision must be served on the attorney

It is valid, provided the respondent forwards the decision to the attorney within a week

One of a member firm's bona fide officers, not an attorney, has filed a Notice of Appearance for the firm. An Adjudicator's order directed to the firm is then sent to the contact employee on its Form BD, and nothing goes to the officer. Has the firm been properly served?

No; the order had to go to the officer and to the contact employee both, one copy each

Yes; a Form BD contact employee is a proper recipient of any order directed to a member firm

Yes; the notice-of-appearance paragraph redirects service only where an attorney has appeared

No; with the officer's notice on file, the order had to be served on the officer

In a Rule 9800 series temporary cease and desist proceeding, a respondent's attorney has filed a notice of appearance but has not agreed to accept service for the respondent. Does the Hearing Panel's decision go to the attorney?

Not on the appearance alone; there the decision goes to counsel who agrees to accept service

Yes; a filed notice of appearance sends every Adjudicator document to the attorney, in any Code proceeding

No; in that series every decision is served on the respondent in person, never on counsel

Yes, but it must also go to the respondent, a Panel decision being served on both

A Hearing Officer's staff propose to e-mail the Hearing Officer's order in a disciplinary proceeding to the parties, relying on the e-mail route in Rule 9132(b). May they do so as of right?

Yes; e-mail is available to every Adjudicator, the Portal being one option among several

No; that route is given to other Adjudicators, and this order goes through the Portal

Yes, provided each party supplied an e-mail address for service in its first filing in the case

No; the order must go by personal service or mail, e-mail being kept for final decisions

An appeal follows a Hearing Panel decision that was served through the OHO Portal. The National Adjudicatory Council's staff upload the Council's decision to the Portal, where every party still has access, and send it by no other means. How does service of the Council's decision stand?

Complete on upload, every party still having Portal access from the hearing that preceded the appeal

Complete for each party at the moment that party first opens the decision in the Portal

Complete, since no party objected in writing to the Council using the Portal for its decision

Not yet made; the Council has no Portal route and must use another method

A respondent files an answer, then stops taking part and fails to appear at a pre-hearing conference of which he had due notice. The Hearing Officer issues a default decision. How is it served?

By personal service, mail or courier, the non-appearance making it a case of default

Through the OHO Portal, since the carve-out reaches a respondent who never answered

Through the OHO Portal, since filing an answer showed he had established Portal access

By e-mail to the address he supplied with his answer, his first filing in the case

The National Adjudicatory Council mails its decision in an appeal to an unrepresented respondent by ordinary first class mail, not certified mail or Express Mail. Is that class of mail permitted for it?

No; first class mail is reserved for papers the parties exchange with each other

No; a decision ending an appeal must go by certified mail or Express Mail

Yes; the certified-or-Express restriction applies to a complaint served on a Respondent

Yes, provided the Council also e-mails the decision to the respondent the same day

The National Adjudicatory Council issues an order setting a period for the parties to respond and serves it on an unrepresented respondent by first class certified mail. How long does that respondent have to respond?

The prescribed period exactly, the addition covering ordinary first class mail and no tracked class

The prescribed period exactly, the Council's orders carrying no allowance for postal delay

The prescribed period, counted from the day the order is delivered to the respondent

The prescribed period plus three days, certified mail being among the classes that attract it

The Council's staff know that an unrepresented registered representative's residential address in the Central Registration Depository is out of date, because earlier mail came back. They mail the decision to her last known residential address and nowhere else. Has she been properly served?

No; a duplicate had to go to the Depository business address of the firm employing her

Yes; once mail has come back, the last known residential address takes the recorded one's place

No; the decision had to be sent to the recorded address again first, by certified mail

Yes, provided the copy sent to the last known address is not also returned undelivered

Before a default decision goes out, the Office of Hearing Officers learns that the respondent has moved from both addresses recorded in the Central Registration Depository, and finds where the respondent now lives. May the decision be served there?

No; a default decision must go to the recorded addresses, which fix the start of its finality period

Yes, on the Hearing Officer's waiver, which covers every paper except the one that began the case

Yes, at the staff's own choice, no ruling being needed once the recorded addresses are shown stale

No; a waiver of the recorded addresses is open for the paper that began the case and no other

The Office of Hearing Officers mails a default decision on the 3rd of the month and it arrives on the 6th. Nobody appeals it or calls it for review. From which date does the period after which it becomes final run?

The date the Hearing Officer signed it, whenever it was later put in the mail

The 6th, the date it arrived, a default decision needing actual receipt to count

The 3rd, the date the Office served it, mail service being complete on mailing

The date the Department of Enforcement confirms to the Office that no appeal has been lodged

A default decision is entered against a registered representative who is associated with two member firms. To whom must the Office of Hearing Officers send the decision?

To each of the two firms by service as Parties, which then serve him in turn

To him by service as a Party, the firms learning of it from the public record

To him by service as a Party, and a copy to the firm that holds his registration

To him by service as a Party, and a copy to each of the two firms

A default decision bars the respondent from association with any member. Which of these ways of getting the decision to him meets the service requirement for it?

Send it by courier to his residential address in the Central Registration Depository

Upload it to the OHO Portal and e-mail him to say that it is there

Send it by ordinary first class mail to his residential address in the Central Registration Depository

Leave it with the person in charge at the office of the member firm he has left

After a contested hearing, one Panelist writes a dissent from the Hearing Panel's decision. What becomes of the dissent?

It stays in the case file, open to the Parties but not served on them

The Office of Hearing Officers serves it on the Parties together with the decision

It goes to the National Adjudicatory Council if an appeal is taken, and not to the Parties

The dissenting Panelist serves it on the Parties personally, apart from the majority's decision

A respondent moves for an extension of time, and the Hearing Officer grants it by order. The respondent assumes the Office of Hearing Officers will serve both the motion and the order on the other Parties. What is wrong with the respondent's assumption?

The respondent must serve both, since the order decides a motion that the respondent itself chose to bring

Nothing; the Office serves every paper filed with it in the case, motions and orders alike, on each Party

The respondent serves its own motion on each Party; the order is the one the Office serves

The Department of Enforcement serves both, as the party that keeps the case record in its own proceeding

FINRA Rule 9132 | Financial Regulation Courses

Service of Orders, Notices, and Decisions by Adjudicator

SERIES 24 | FINANCIAL REGULATION COURSES

FINRA Rule 9132 governs the service of the most authoritative documents in any Code of Procedure proceeding — the orders, notices, and decisions issued by Adjudicators. These are the formal rulings that shape every stage of a FINRA disciplinary proceeding: the scheduling orders that set hearing dates, the evidentiary rulings that govern what evidence may be presented, the procedural orders that resolve motions, the Hearing Panel decision that determines guilt and sanction at the first level of adjudication, the National Adjudicatory Council decision that resolves any appeal, and every other Adjudicator-issued document that affects the parties' rights and obligations. FINRA Rule 9132 establishes two core requirements: which body or person is responsible for serving Adjudicator-issued documents on the parties, and how that service is accomplished. The rule draws a fundamental distinction between documents issued by Hearing Officers, Hearing Panels, and Extended Hearing Panels in OHO proceedings — served primarily through the OHO Portal — and documents issued by all other Adjudicators — served by traditional methods or email.

FINRA Rule 9132 sits within the 9130 Service; Filing of Papers subsection of the 9100 Application and Purpose section of the 9000 Code of Procedure series. Its history runs from an amendment effective October 18, 1990 and an amendment by SR-NASD-97-28 effective August 7, 1997, through SR-FINRA-2008-021 effective December 15, 2008 as part of the consolidated FINRA rulebook transition announced in Regulatory Notice 08-57, and SR-FINRA-2022-009 effective August 22, 2022 as announced in Regulatory Notice 22-16, which authorized email service of Adjudicator-issued documents outside OHO, to the most recent amendment, SR-FINRA-2025-013 effective October 7, 2025 as announced in Regulatory Notice 25-10, which added the OHO Portal as the primary service method for OHO proceedings; SR-NASD-99-76 (September 11, 2000), SR-FINRA-2011-044 (March 30, 2012, Regulatory Notice 12-12) and SR-FINRA-2018-027 (August 3, 2018) amended other Code of Procedure rules such as FINRA Rule 9131 but are not listed in this rule's amendment history.

FINRA Rule 9132(a): Service Responsibility

FINRA Rule 9132(a) establishes two distinct service responsibility standards depending on which Adjudicator issued the document.

For orders, notices, and decisions issued by a Hearing Officer, Hearing Panel, or Extended Hearing Panel in proceedings under the Rule 9200 series — the disciplinary proceedings before OHO — service on each party, each party's counsel, or other person designated to represent a party shall be made by the Office of Hearing Officers. OHO as an institution, rather than the individual Hearing Officer personally, bears the administrative responsibility for ensuring that orders and decisions reach the parties. This institutional service responsibility reflects OHO's role as the administrative body managing the proceeding — OHO staff process, transmit, and document the service of all Adjudicator-issued documents in OHO proceedings, creating a centralized and auditable service record.

For orders, notices, and decisions issued by any other Adjudicator — the National Adjudicatory Council, the Review Subcommittee, the Extended Proceeding Committee, the Statutory Disqualification Committee, the FINRA Board, and any other adjudicative body operating outside the OHO framework — service shall be made by that Adjudicator. The NAC serves its own decisions on the parties; the FINRA Board serves its own decisions; each adjudicative body outside OHO takes responsibility for serving its own output. This distributed responsibility reflects the organizational separation between OHO — a standalone office within FINRA dedicated to first-level adjudication — and the appellate and other adjudicative bodies that operate through different organizational structures within FINRA.

The service obligation extends expressly to each party's counsel when counsel has filed a notice of appearance under FINRA Rule 9141. Once a notice of appearance is on file, service on counsel satisfies the service obligation with respect to that party — the Adjudicator need not separately serve the party directly. The Adjudicator retains discretion to order that service also be made directly on the party in addition to counsel, but absent such an order, counsel service alone is complete.

FINRA Rule 9132(b): How Adjudicator-Issued Documents Are Served

FINRA Rule 9132(b) establishes the service method framework, drawing the fundamental distinction between OHO proceedings and all other proceedings.

For OHO proceedings — orders, notices, and decisions issued by a Hearing Officer, Hearing Panel, or Extended Hearing Panel — the primary service method following the October 2025 amendment is through the OHO Portal. Service through the OHO Portal is deemed complete upon submission of the document to the Portal. This means that when OHO uploads an order or decision to the OHO Portal, service on all parties who have Portal access is complete at that moment — not when any party actually downloads or reads the document. The instantaneous completion of Portal service upon submission creates a precise, verifiable timestamp for service that is logged automatically in the Portal's audit system, eliminating disputes about when service occurred.

Two exceptions to OHO Portal service apply. First, an alternative method of service may be ordered by the Hearing Officer, Hearing Panel, or Extended Hearing Panel — preserving Adjudicator flexibility to direct service by other means in unusual circumstances such as a party lacking Portal access or a document requiring verified receipt. Second, in cases of default under FINRA Rules 9215(f) and 9269(a) — where a respondent has failed to answer or participate in the proceeding — service of orders, notices, and decisions shall be made pursuant to paragraphs (a) and (b) of FINRA Rule 9134, meaning personal service or mail and courier rather than OHO Portal. This exception governs the documents an Adjudicator issues in a default case, chiefly the default decision under FINRA Rule 9269(a); the second notice under FINRA Rule 9215(f) is issued by the Department of Enforcement rather than by an Adjudicator, and reaches the same personal-service-or-mail standard through FINRA Rule 9134(c)(1)(B) rather than through this Rule. This default exception reflects the policy that a non-participating respondent who may not be actively monitoring the OHO Portal requires the most reliable traditional service methods to ensure that default orders and decisions have the best chance of actual receipt.

For non-OHO proceedings — orders, notices, and decisions issued by any other Adjudicator — service shall be made pursuant to paragraphs (a) and (b) of FINRA Rule 9134, meaning personal service or mail and courier, or by electronic mail. The addition of electronic mail as an authorized method for non-OHO Adjudicator decisions was one of the key changes made by the August 2022 amendment through SR-FINRA-2022-009. Prior to that amendment, FINRA Rule 9132(b) directed all service of Adjudicator-issued documents to FINRA Rule 9134's traditional personal service and mail methods — email was not authorized. The 2022 amendment recognized that email service of NAC decisions, Board decisions, and other non-OHO Adjudicator outputs is both efficient and reliable, and added it as an authorized option alongside the traditional methods.

The Significance of OHO Portal Service for Adjudicator Documents

The shift to OHO Portal service as the primary mechanism for OHO-issued orders, notices, and decisions reflects a fundamental modernization of the disciplinary proceeding infrastructure. Under the prior systems, OHO would email orders and decisions to parties and their counsel, and before 2020 would mail or courier them — a process that, on paper, introduced delay, created uncertainty about delivery, and required physical document handling by OHO staff. Under the Portal-based system, OHO uploads the document to the Portal and service is instantly complete for all Portal-enabled parties.

The OHO Portal's service function for Adjudicator documents operates in tandem with its filing function for party-submitted documents under FINRA Rule 9135. Both functions run through the same electronic infrastructure, creating a unified case management system in which all documents — whether issued by the Adjudicator or filed by the parties — flow through the Portal and are accessible to all parties with Portal access. This integrated system creates a complete and accessible case record that all parties can review at any time, replacing the prior system in which the authoritative case record was a physical file maintained at OHO's offices.

The practical obligation for parties in OHO proceedings is to maintain active OHO Portal access and to monitor the Portal regularly for new documents. Because service of Adjudicator-issued orders is complete upon Portal submission — not upon actual review by the party — a party who neglects to check the Portal and misses a scheduling order or procedural deadline cannot claim that lack of actual notice defeats service. The Portal service completion standard places the monitoring burden on the parties rather than on OHO, which is consistent with the general principle that parties in adversarial proceedings bear responsibility for staying current with the case record.

The Default Service Exception: FINRA Rules 9215(f) and 9269(a)

The carve-out requiring personal service, mail or courier service for Adjudicator documents in default cases under FINRA Rules 9215(f) and 9269(a) reflects an important policy judgment about the treatment of non-participating respondents.

FINRA Rule 9215(f) addresses the situation where a respondent fails to file an answer within the required period — the first stage of potential default. When a respondent has not filed an answer, the Department of Enforcement sends a second notice requiring an answer within fourteen days after service of that notice. That second notice is issued by a party rather than by an Adjudicator, so it falls outside FINRA Rule 9132 — but FINRA Rule 9134(c)(1)(B) requires that papers in default cases under Rules 9215(f) and 9269(a) be served under paragraphs (a) and (b) of Rule 9134, personal service, mail or courier, rather than through the OHO Portal, because a respondent who has not answered the complaint may not have established Portal access or may not be monitoring it. FINRA Rule 9269(a) governs the default decision itself — when no answer is filed after the second notice, the Hearing Officer may issue a default decision. That decision must also be served by personal service, mail or courier — and, where the sanction is a bar or an expulsion, by courier, facsimile or other means reasonably likely to obtain prompt service under FINRA Rule 9269(d) — to ensure that the respondent has the best possible chance of actual notice of the default outcome and the consequences flowing from it.

The policy underlying this exception is sound: a respondent who has not participated in the proceeding may not have Portal access, may not be monitoring electronic communications, and may be genuinely unaware that a proceeding is pending. The default service exception ensures that the most consequential documents in a default proceeding — the notices demanding a response and the ultimate default decision — are served through methods most likely to achieve actual delivery, protecting both the integrity of the proceeding and the respondent's due process interests to the maximum extent possible.

Connection to FINRA Rules 9131, 9133, and 9134

FINRA Rule 9132 occupies a specific position in the three-rule service typology established by the 9130 subsection. FINRA Rule 9131 governs the service of the complaint — the initiating document served by the Department of Enforcement on each respondent using personal service or mail. FINRA Rule 9132 governs the service of Adjudicator-issued documents — the orders, notices, and decisions that flow from the Adjudicator to the parties throughout the proceeding. FINRA Rule 9133 governs the service of all other papers — the inter-party documents such as answers, motions, and briefs that the parties serve on each other throughout the proceeding. Together these three rules cover every document service event in a Code proceeding without overlap: the complaint flows outward from FINRA enforcement to respondents under FINRA Rule 9131; official rulings flow outward from the Adjudicator to parties under FINRA Rule 9132; party submissions flow laterally between parties under FINRA Rule 9133. FINRA Rule 9134 provides the service method definitions that all three rules invoke.

Across the Full Range of Code Proceedings

While FINRA Rule 9132 is most directly applicable to Rule 9200 series disciplinary proceedings before OHO and Rule 9300 series appellate proceedings before the NAC, its service framework extends across all Code proceedings by operation of FINRA Rule 9110(a)'s universal applicability principle. In expedited proceedings under the Rule 9550 series, orders and decisions issued by the Hearing Officer or Hearing Panel are served through the OHO Portal for OHO proceedings and by traditional methods or email for other proceedings. In statutory disqualification proceedings under the Rule 9520 series, the Hearing Panel presents a recommended decision, and the final decisions of the NAC, or of the FINRA Board or the Statutory Disqualification Committee where they decide, are served pursuant to FINRA Rule 9132 and FINRA Rule 9134, with electronic mail also available. In temporary cease and desist proceedings under the Rule 9800 series, the Office of Hearing Officers serves the Hearing Panel's decision and any cease and desist order through the series' own provision, which applies FINRA Rule 9134(c) rather than FINRA Rule 9132 and reaches counsel when counsel agrees to accept service. The rule's cross-proceeding applicability makes its service framework the universal standard for official FINRA adjudicative output across the entire disciplinary system.

Service by Other Adjudicators in Practice

FINRA Rule 9132(b) gives every Adjudicator other than a Hearing Officer, Hearing Panel or Extended Hearing Panel two routes. The first is the methods in paragraphs (a) and (b) of FINRA Rule 9134. The second is electronic mail. The National Adjudicatory Council, the Review Subcommittee and the other appellate and review bodies serve their orders, notices and decisions by one of these routes.

When the route is electronic mail, FINRA Rule 9132(b) fixes the moment of service. Service by electronic mail is deemed complete upon sending the order, notice or decision. Suppose the National Adjudicatory Council e-mails its decision in an appeal on a Tuesday, and the recipient first opens the message on the Friday. Service was complete on the Tuesday, when the decision was sent. It does not wait for the recipient to open, read or acknowledge the message.

When the route is FINRA Rule 9134, courier service is available as well as personal service and mail. FINRA Rule 9134(a) lists three methods: personal service, service by mail through the U.S. Postal Service, and service by courier. Service by courier is made by sending the papers through a courier service that generates a written confirmation of receipt or of attempts at delivery. A National Adjudicatory Council decision sent that way has been served by a method FINRA Rule 9132(b) permits. Under FINRA Rule 9134(b)(3), courier service is complete upon delivery, and service by mail is complete upon mailing.

FINRA Rule 9132(c): Service on Counsel and Representatives

FINRA Rule 9132(c) applies "whenever service is required to be made upon a person represented by counsel or a representative who has filed a notice of appearance pursuant to Rule 9141". In that case service "shall be made upon counsel or the representative". The paragraph is not confined to the Office of Hearing Officers. It governs an order of a Hearing Officer and a decision of the National Adjudicatory Council alike.

Consider an appeal in which the respondent's attorney has filed a notice of appearance with the National Adjudicatory Council. When the Council issues its decision, service is to be made on that attorney. The Council may serve the attorney by e-mail or by a FINRA Rule 9134 method. Sending the decision only to the respondent's own e-mail address is not the service on counsel that FINRA Rule 9132(c) requires. The Council may, at its discretion, also order that service be made on the respondent. That order adds the respondent as someone to serve; it does not replace the attorney.

The paragraph covers representatives who are not attorneys. Under FINRA Rule 9141(b), a bona fide officer of a corporation may represent the corporation. A person who first appears in a representative capacity must file a Notice of Appearance. Once a member firm's officer has filed that notice on the firm's behalf, orders, notices and decisions directed to the firm are served on the officer as its representative, in the same way they would be served on counsel.

The trigger in FINRA Rule 9132(c) is a filed notice of appearance. Some sibling rules use a different trigger. In a temporary cease and desist proceeding, FINRA Rule 9840 has the Office of Hearing Officers serve the Hearing Panel's decision and any cease and desist order on the Department of Enforcement and the Respondent. They are served on the Respondent's counsel or other authorized representative "when counsel or other person authorized to represent others under Rule 9141 agrees to accept service for the Respondent". Service is made pursuant to FINRA Rule 9134(c). In that proceeding, counsel's agreement to accept service is what sends the order to counsel.

Portal Service Follows the Issuing Adjudicator

FINRA Rule 9132(b) attaches the OHO Portal requirement to the Adjudicator that issued the document. An order, notice or decision issued by a Hearing Officer, Hearing Panel or Extended Hearing Panel is served through the OHO Portal, unless one of them orders an alternative method of service. The electronic mail option in the same paragraph is given to "any other Adjudicator". A Hearing Officer's order in a disciplinary proceeding therefore goes through the Portal. It is not e-mailed to the parties unless an alternative method of service has been ordered.

The Portal requirement is not limited to Rule 9200 series disciplinary proceedings. The Office of Hearing Officers is also the forum for expedited proceedings and for temporary cease and desist hearings, and Hearing Officers act in the Rule 9550 and Rule 9800 series. An order that a Hearing Panel issues in a Rule 9550 series expedited proceeding before the Office of Hearing Officers is served through the OHO Portal. FINRA Rule 9134(c) makes the Portal the required method for papers served in proceedings before the Office of Hearing Officers, and FINRA Rule 9134(c)(3) permits it in no other proceeding.

Service through the Portal reaches every Party, and in a disciplinary proceeding the Department of Enforcement is a Party. FINRA Rule 9132(a) requires an order issued by a Hearing Officer, Hearing Panel or Extended Hearing Panel under the Rule 9200 series to be served "on each Party". FINRA Rule 9120 defines Party in the Rule 9200 series as "the Department of Enforcement or a Respondent". A scheduling order is therefore served on the Department of Enforcement as well as on each respondent. The Department is the party that brought the case, but that does not exempt it from service.

Worked Scenario: Serving Documents in a Default Case

A complaint names Mr. Vance, a registered representative. He files an answer and then stops taking part. He does not appear at the pre-hearing conference held under FINRA Rule 9241, although he had due notice of it. FINRA Rule 9269(a)(1) allows the Hearing Officer to issue a default decision against a Party who fails to appear at such a conference. So a case of default under FINRA Rule 9269(a) does not require a failure to answer. Mr. Vance answered, but his case is still a case of default.

In a case of default under FINRA Rule 9269(a), FINRA Rule 9132(b) takes the default decision out of Portal service. The decision is served under paragraphs (a) and (b) of FINRA Rule 9134, meaning personal service, mail or courier at the addresses those paragraphs permit. This applies to Mr. Vance's default decision even though his answer was filed while he was taking part.

The carve-out covers every order, notice or decision a Hearing Officer, Hearing Panel or Extended Hearing Panel issues in the default case, not only the decision. FINRA Rule 9269(a)(3) lets the Hearing Officer order a Party who fails to appear at the pre-hearing conference or the hearing to pay the costs other Parties incurred in appearing. If the Hearing Officer orders Mr. Vance to pay those costs, that order is served by personal service, mail or courier as well, not through the Portal.

The carve-out changes the method of service, not who serves. The documents were issued by a Hearing Officer under the Rule 9200 series, so the Office of Hearing Officers still serves them under FINRA Rule 9132(a). FINRA Rule 9269(d) refers to "the date the Office of Hearing Officers serves" a default decision on the Parties. If the default decision bars Mr. Vance, FINRA Rule 9269(d) adds a requirement: FINRA must serve the decision on him by courier, facsimile or other means reasonably likely to obtain prompt service.

Common Errors in Serving Adjudicator-Issued Documents

One common error is treating the e-mail route as available to every Adjudicator. FINRA Rule 9132(b) gives electronic mail to Adjudicators other than a Hearing Officer, Hearing Panel or Extended Hearing Panel. The documents those three issue go through the OHO Portal unless an alternative method of service is ordered.

A second is measuring e-mail service from when it was read. Service by electronic mail of an order, notice or decision is deemed complete upon sending.

A third is serving the represented person instead of the representative. Once counsel or a representative has filed a notice of appearance under FINRA Rule 9141, FINRA Rule 9132(c) requires service to be made on counsel or the representative. Service on the person as well requires an order of the Adjudicator.

A fourth is using the Portal in a default case. In cases of default under FINRA Rules 9215(f) and 9269(a), orders, notices and decisions of a Hearing Officer, Hearing Panel or Extended Hearing Panel are served under paragraphs (a) and (b) of FINRA Rule 9134. That includes a case where a respondent who answered later failed to appear.

Traditional Service by Other Adjudicators: Methods, Addresses and Timing

When an Adjudicator outside the Office of Hearing Officers serves by the traditional route, FINRA Rule 9132(b) brings in both paragraphs of FINRA Rule 9134. Paragraph (a) sets the methods. Paragraph (b) sets whom and where to serve, and when service is complete. Consider a National Adjudicatory Council decision in an appeal by Ms. Reyes, a registered representative who is not represented. FINRA Rule 9134(a)(1) allows personal service in three ways. The decision may be handed to her. It may be left at her office with an employee or other person in charge. Or it may be left at her dwelling or usual place of abode with a person of suitable age and discretion then residing there. So a decision left with her adult son, who lives at her home, has been personally served even though she was away.

If the Council mails the decision, FINRA Rule 9134(a)(2) allows first class mail, first class certified mail, first class registered mail or Express Mail. The restriction to certified mail or Express Mail applies only to a complaint served on a Respondent. A decision is not a complaint, so ordinary first class mail is a permitted class for it.

The method chosen fixes when service is complete. Under FINRA Rule 9134(b)(3), personal service and courier service are complete upon delivery, and service by mail is complete upon mailing. A decision mailed on the 3rd of the month is served on the 3rd, even if it arrives on the 6th. The same decision sent by courier on the 3rd and delivered on the 4th is served on the 4th.

The method also affects any response period that the Adjudicator's order sets. FINRA Rule 9138(c) adds three days to the prescribed period for response if service is made by U.S. Postal Service first class, certified, or registered mail. Suppose the Council's order sets a period for the parties to respond and is served on Ms. Reyes by first class mail. She has the prescribed period plus three days.

The address follows FINRA Rule 9134(b)(1). Papers for a natural person may be served at the residential address reflected in the Central Registration Depository. Suppose the Council's staff actually know that Ms. Reyes's address there is out of date, because earlier mail came back. Then duplicate copies must be served at her last known residential address and at the Central Registration Depository business address of the firm with which she is employed or affiliated. Papers may also go to that firm's recorded business address, or to a branch office where she works or is physically present during a normal business day.

Where the party is a member firm, FINRA Rule 9134(b)(2) directs service to an officer, a partner of a partnership, a managing or general agent, a contact employee as set forth on Form BD, or any other agent authorized by appointment or by law to accept service. It is made at the firm's business address as reflected in the Central Registration Depository. If the firm's counsel or representative has filed a notice of appearance, FINRA Rule 9132(c) sends the document to that counsel or representative instead.

The National Adjudicatory Council cannot use the OHO Portal as its route. FINRA Rule 9134(c)(3) says service through the OHO Portal is only permissible in proceedings before the Office of Hearing Officers and may not be used in any other proceeding. Regulatory Notice 25-10 adds that the Portal "does not support service or filing of documents in National Adjudicatory Council (NAC) proceedings". The Council's choices are the FINRA Rule 9134(a) and (b) methods and electronic mail.

E-mail service depends on the address on file. Under FINRA Rule 9135(d), a Party's first filing must include a mailing address and an electronic mail address at which notices, orders and other communications required to be served on the Party may be sent. A Party whose mailing or e-mail address changes during a proceeding must serve the change on all other Parties and file it with the Adjudicator. A respondent who changes e-mail provider during an appeal therefore serves and files the new address. The Council's e-mailed decision can then reach the address that is current.

Worked Scenario Continued: The Default Decision in Practice

Return to Mr. Vance, whose default decision is to be served by the traditional methods. Suppose the Office of Hearing Officers has evidence that his Central Registration Depository addresses are no longer valid, and a more current address is available. FINRA Rule 9134(b)(1) lets the Hearing Officer waive the requirement to serve at the Central Registration Depository addresses for documents other than complaints. The default decision is not a complaint, so the waiver is available, and the decision may be served at the more current address.

If the default decision imposes a bar, FINRA Rule 9269(d) sets a further requirement. FINRA must serve the decision on him by courier, facsimile or other means reasonably likely to obtain prompt service. A bar becomes effective immediately once the default decision becomes FINRA's final disciplinary action, which is why prompt service matters.

The date of service matters for finality. Under FINRA Rule 9269(d), a default decision that is not appealed under FINRA Rule 9311 or called for review under FINRA Rule 9312 becomes FINRA's final disciplinary action on a set timetable. The period is 25 days, and it runs from the date the Office of Hearing Officers serves the decision on the Parties. Because the decision goes by the traditional methods, that date is fixed by FINRA Rule 9134(b)(3). If the decision is served by mail, it is the date of mailing.

Serving the Parties is not the only distribution. FINRA Rule 9269(a)(4) also requires the Office of Hearing Officers to provide a copy of the default decision to each FINRA member with which the Respondent is associated. That copy goes to the member firm, which is not a Party, so it is in addition to service on Mr. Vance.

Adjudicator Documents Alongside Party Papers and the Hearing Panel Decision

Within the 9130 service subsection, FINRA Rule 9132 governs what the Adjudicator issues, and FINRA Rule 9133 governs what the parties exchange. A single motion therefore moves under both. Suppose a respondent moves for an extension. The respondent, or the respondent's counsel or representative, serves the motion on each Party under FINRA Rule 9133(a). The Hearing Officer's order deciding it is then served on the Parties under FINRA Rule 9132 by the Office of Hearing Officers.

The Hearing Panel's decision after a contested hearing is also an Adjudicator-issued document. FINRA Rule 9268(d) requires the Office of Hearing Officers to promptly serve the decision, and any dissenting opinion, on the Parties. A Hearing Officer or Panelist may prepare a dissent under FINRA Rule 9268(c). If one does, the dissent is served with the decision; it does not stay in the case file. Under FINRA Rule 9132(b), both are served through the OHO Portal unless an alternative method has been ordered or the case is one of default.

Examination Relevance and Key Takeaways

FINRA Rule 9132 is tested on the Series 24 General Securities Principal examination in the context of the Code of Procedure's service framework, the procedural infrastructure of FINRA disciplinary proceedings, and the distinction between different categories of documents and the service methods applicable to each. The August 2022 modernization adding email service and the October 2025 amendment adding OHO Portal service for Adjudicator-issued documents are current and examination-relevant material for candidates sitting after October 2025.

The key points to retain are these: FINRA Rule 9132 governs the service of all orders, notices, and decisions issued by Adjudicators throughout Code of Procedure proceedings; for OHO proceedings, the Office of Hearing Officers is the serving body and service is accomplished primarily through the OHO Portal — complete upon submission to the Portal — unless the Adjudicator orders an alternative method; for all other Adjudicators — the NAC, Review Subcommittee, FINRA Board, and all other adjudicative bodies outside OHO — service is made pursuant to FINRA Rule 9134's personal service, mail and courier methods or by electronic mail; in cases of default under FINRA Rules 9215(f) and 9269(a), even OHO-issued documents must be served by personal service, mail or courier rather than through the OHO Portal — ensuring that non-participating respondents receive the most reliable service methods for the most consequential default notices and decisions; when a party is represented by counsel who has filed a notice of appearance under FINRA Rule 9141, service on counsel satisfies the service obligation with the Adjudicator retaining discretion to order direct service on the party as well; the OHO Portal service mechanism was established as the primary OHO service method by SR-FINRA-2025-013 effective October 7, 2025, announced in Regulatory Notice 25-10, replacing email, which SR-FINRA-2022-009 effective August 22, 2022, announced in Regulatory Notice 22-16, had made permanent after electronic service methods were temporarily adopted during the COVID-19 pandemic beginning May 2020; and parties in OHO proceedings bear the responsibility of maintaining active Portal access and monitoring it regularly because OHO Portal service is complete upon submission regardless of whether the party has actually reviewed the document.