A Hearing Officer must prepare the written decision within sixty days. From what event does that period run?

The conclusion of the hearing at which the evidence was taken

The final date allowed for filing post-hearing submissions

The date on which the Hearing Panel completes its deliberations

The date the complete hearing transcript is delivered to the Panel

A multi-respondent proceeding has generated a very large record and the Hearing Officer will not have a decision ready in sixty days. What does FINRA Rule 9268(a) allow?

The Panel to issue its conclusions first and its reasons within a further period

An extension on the parties' joint application, granted for good cause shown

The Chief Hearing Officer to establish a different date for the decision

Nothing; the sixty days is fixed and applies to every proceeding alike

One required element of a decision is a statement describing how the disciplinary proceeding originated. When must it be included?

Only where the origin is not otherwise contained in the record

Only where the proceeding began from a customer complaint or a self-report

In every decision, the origin being part of the required narrative in all cases

Only where a respondent has put the origin of the proceeding in issue

A complaint pleads four causes of action. What does the conclusions element of FINRA Rule 9268(b) require the decision to do about them?

Reach one overall finding of violation or no violation on the complaint as a whole

Determine each of the four, so no charged cause is left without a conclusion

Determine the causes on which a sanction is imposed, the others needing no finding

Determine only those the Panel found established, the remainder falling away silently

Beyond findings of fact and conclusions on each charge, FINRA Rule 9268(b) requires a further statement about the principal issues in the proceeding. What must that statement do?

Set out the arguments the Panel considered but did not need to decide

Identify which issues the parties agreed were principal to the case

Explain why the Panel disposed of those issues as it did

Summarise the evidence each party put before the Panel on those issues

The majority decision is due within sixty days. What period applies to a dissenting opinion, and why does it differ?

No fixed period, a dissent being filed at any time before the decision is served

Sixty days also, both being prepared in parallel from the same starting point

Ninety days, a dissent requiring the complete record rather than the deliberations

Sixty-five days, giving the dissenter sight of the majority's reasoning first

Who may prepare a dissenting opinion in a FINRA disciplinary proceeding?

The Hearing Officer or any Panelist, whoever is in the minority

Any Panelist, provided the other Panelist joins in the dissent as well

Either Panelist, the Hearing Officer being the author of the majority decision

Either Panelist, and the Hearing Officer only on a question of law

Beyond serving the decision on the parties, what must the Office of Hearing Officers do with it?

File it with the Commission, which publishes it in the Federal Register in due course

Publish notice of it, and of any dissent, in the Central Registration Depository

Circulate it to the Regional Committee from which the Panelists were drawn

Post it on FINRA's website for the period during which an appeal may be brought

The period for challenging a Hearing Panel decision is twenty-five days. From what event does it run?

The date the Hearing Officer signs the decision and transmits it to the Office

Publication of notice of the decision in the Central Registration Depository

Service of the decision on the parties

The date on which the sanctions imposed by the decision take effect

A decision becomes final disciplinary action. It imposes a fine on one respondent and a bar on another. When does each take effect?

Both on a date FINRA determines, which may differ between the two respondents

The fine immediately; the bar once the barred person's firm has been notified

Both immediately, finality being the single event that brings sanctions into force

The fine on a date FINRA determines; the bar immediately upon finality

A Hearing Panel considers that a sanction taking effect on the default timetable would fall at a moment particularly disruptive for a firm's clients. What is open to it?

Providing for a different effective date in the majority decision itself

Recommending a date to FINRA staff, who decide whether to adopt it

Nothing; the effectiveness rules are fixed and the firm must apply for relief later

Suspending the sanction until the disruption the firm identifies has passed

A respondent appeals a Hearing Panel decision to the National Adjudicatory Council. What happens to the sanctions the decision imposed while that appeal is pending?

They take effect as the decision provides, an appeal not disturbing them

They are stayed automatically, without any order being needed

They take effect unless the Hearing Officer directs otherwise on the appeal

They are stayed only if the Council orders a stay on the respondent's application

One kind of order in a Hearing Panel decision is not held in suspense by an appeal to the Council. Which, and on what reasoning?

A suspension, because its period would otherwise be extended by the length of the appeal

An order for costs, because it does not restrict the respondent's activities

A permanent order to cease and desist, because the conduct cannot be left running

A fine, because the money can be returned if the appeal succeeds

FINRA Rule 9268(a) directs the Hearing Officer to prepare the Hearing Panel's written decision. How does the Hearing Officer's role in preparing it relate to what the decision concludes?

The Officer drafts it, but its conclusions are the Panel majority's, as fixed by majority vote

The Officer drafts it from a unanimous view, a divided Panel referring the case to the Chief Hearing Officer

The Officer decides the outcome as presiding officer, the Panelists advising on the findings of fact

The Officer's own analysis governs the reasoning, while the Panel's vote fixes only the sanction

Under the default standards, FINRA Rule 9266 allows sixty days after the hearing ends for post-hearing submissions, and FINRA Rule 9268(a) allows sixty days for preparing the written decision. What is the longest the post-hearing period can run before the decision issues?

Up to 90 days, the drafting window overlapping the last thirty days of briefing

Up to 120 days, the two windows running one after the other

Up to 180 days, a further sixty being allowed for the Panel's deliberations

Up to 60 days, the two windows running concurrently from the end of the hearing

A Hearing Panel finds violations and imposes sanctions for them. Under FINRA Rule 9268(b), what must the decision's statement about those sanctions contain?

A description of each sanction, its reasons being left to a separate order issued after finality

A description of each sanction and the Sanction Guidelines range it falls within, and nothing more

A description of each sanction, the reasons for it, and the date it becomes effective

A description of each sanction and the reasons for it, with a comparison to sanctions in prior decisions

A Panelist agrees with the majority that the respondent committed the violation but considers the sanction the majority imposed far too severe. May that Panelist write a dissenting opinion?

No; a dissent is confined to disagreement over whether the respondent committed a violation at all

Only if the Hearing Officer certifies that the sanction question warrants a separate written opinion

No; a disagreement over sanction is recorded as a footnote in the majority decision instead

Yes; a dissent may rest on a materially different view of the sanction alone

A Hearing Panel decision finding a violation is accompanied by a dissent from one Panelist, and the respondent appeals. What part can the dissent play in the appeal?

It can strengthen the respondent's arguments by showing where reasonable adjudicators disagreed

It obliges the Council to decide the issues it raises before turning to any others

None; the dissent is withdrawn from the record once the majority decision has been served

It reopens the hearing so that the dissenting Panelist's view can be tested by evidence

A respondent found to have violated FINRA rules is currently associated with a member firm. Beyond serving the parties, what does FINRA Rule 9268(d) require the Office of Hearing Officers to do in relation to that firm?

Nothing; the firm learns of the decision from the respondent or from the public record

Provide the firm with a copy of the decision, so that it can take supervisory action

Direct the firm to file a heightened supervision plan within ten days of the decision

Notify the firm only where the decision imposes a bar, a suspension or an expulsion on the respondent

FINRA Rule 9268(d) requires the Office of Hearing Officers to serve a Hearing Panel decision, and any dissenting opinion, on the parties promptly, but prescribes no method for doing so itself and cross-refers to another provision of the disciplinary code. What kind of provision does it point to?

The provision governing filing with the Adjudicator, a decision reaching the parties by being placed in the case record

The provision governing the papers the parties themselves exchange, the decision entering the proceeding as one more paper in the case

The code's general rule for serving documents an Adjudicator has issued, which reaches the decision as it reaches any such document

A provision written for Hearing Panel decisions specifically, under which delivery is complete only once the recipient acknowledges receipt

No party appeals a Hearing Panel decision, but within the applicable period it is called for review under FINRA Rule 9312. Does the decision become FINRA's final disciplinary action?

Yes; only a party's appeal under Rule 9311 prevents a Hearing Panel decision becoming final

No; a call for review sends the case back to the same Hearing Panel for a fresh decision

Yes; a call for review is heard only after the decision has already taken effect as final

No; finality requires that there be neither a timely appeal nor a timely call for review

A Hearing Panel decision becomes FINRA's final disciplinary action for purposes of SEA Rule 19d-1(c)(1). What does that finality trigger under the Exchange Act rule?

FINRA's obligation to report the final disciplinary action to the SEC

The SEC's obligation to review the decision before any of its sanctions take effect

FINRA's obligation to publish the full text of the decision in the Federal Register

The member firm's obligation to place the respondent under heightened supervision

A Hearing Panel suspends a registered representative and considers that investor protection requires the suspension to take effect as soon as the decision is final. Can the Panel achieve that?

Only by asking the Chief Hearing Officer to issue a separate order to that effect

Yes, by providing for immediate effectiveness in the majority decision itself

Yes, though that needs the respondent's written consent to the earlier date

No; the Panel may postpone a sanction's effective date but never bring it forward

A Hearing Panel decision imposing a three-month suspension becomes final, and the date on which the suspension begins is fixed afterwards rather than at the moment of finality. What is that arrangement designed to allow?

A period in which the respondent may pay any fine in instalments before being suspended

A chance for the Hearing Panel to reconsider the length of the suspension before it begins

A brief period for the respondent to wind down activities or arrange supervision first

A delay long enough for the respondent to complete any appeal to the Commission first

A Hearing Panel decision imposes a six-month suspension and a permanent cease and desist order, and the respondent appeals to the National Adjudicatory Council. What is the position of each sanction while the appeal is pending?

Both are stayed, the appeal suspending the whole decision until the Council rules

The cease and desist order is stayed; the suspension takes effect as the decision provides

Neither is stayed, the respondent having to apply to the Council for a stay

The suspension is stayed; the cease and desist order is not stayed

How does a settlement under FINRA Rule 9270 relate to a Hearing Panel decision under FINRA Rule 9268?

It is an alternative route, ending the proceeding without a written Hearing Panel decision

It is embodied in the Rule 9268 decision, which records the agreed sanctions as findings

It is a required step, attempted before any Rule 9268 decision may be drafted

It follows a Rule 9268 decision, letting the respondent settle the sanction after the finding

At what point relative to a FINRA Rule 9268 decision, and by whom, are interim orders under FINRA Rule 9285 imposed?

After the decision becomes final, by the National Adjudicatory Council

After the decision is appealed, by the Hearing Officer

While the decision is being drafted, by the Chief Hearing Officer

Before the decision issues, by the Hearing Panel as a whole

A Hearing Panel decision bars a registered representative from associating with any member firm, and he files an appeal to the National Adjudicatory Council within the period allowed. What is the position of the bar while that appeal is pending?

It takes effect from the date the Hearing Panel signed its decision, an appeal leaving the operation of the sanctions undisturbed

It is stayed, but only from the date on which the Council accepts the appeal for review, and not from the filing

It is stayed by the appeal itself, so the bar does not take effect while the Council has the case

The appeal reaches only the findings of violation, so the bar continues to operate throughout the appellate period

One Panelist wrote a dissenting opinion in a disciplinary proceeding, and the Hearing Panel's decision has become FINRA's final disciplinary action. Which document stands as that final disciplinary action?

Whichever of the two the National Adjudicatory Council adopts when the Panel's division is placed before it

The majority decision and the dissenting opinion together, the two issuing as one composite decision of the Hearing Panel

The majority decision as to the violations found, the sanctions awaiting a further order once the dissent has been addressed

The majority decision, the dissenting opinion reaching the parties and the public record alongside it without forming part of it

FINRA Rule 9268: Hearing Panel Decisions and Sanctions Effectiveness

Decision of Hearing Panel or Extended Hearing Panel

FINRA Rule 9268 governs the Hearing Panel's written decision — the formal adjudicative output that determines whether the respondent violated any charged rule provision, imposes sanctions where violations are found, and initiates the process through which the decision either becomes final disciplinary action or proceeds to appellate review.

The rule establishes the 60-day decision drafting window measured from the final post-hearing briefing date, the seven required content elements of every decision, the 65-day dissenting opinion window, the service and dissemination requirements that broadcast the decision to the parties and through the CRD system, the finality provision that makes an unappealed decision the final disciplinary action of FINRA, and the sanctions effectiveness framework governing when specific sanctions take effect.

Together these provisions define the complete lifecycle of the Hearing Panel's decision from drafting through finality — the moment when FINRA's formal charging process culminates in either a binding adjudicative outcome or the initiation of appellate review.

FINRA Rule 9268 sits within the 9260 Hearing and Decision subsection of the 9200 Disciplinary Proceedings section of the 9000 Code of Procedure series. It was adopted by SR-NASD-97-28 effective August 7, 1997, amended by SR-NASD-99-76 effective September 11, 2000, amended by SR-FINRA-2008-021 effective December 15, 2008, amended by SR-FINRA-2011-044 effective March 30, 2012, amended by SR-FINRA-2013-018 effective December 16, 2013 as announced in Regulatory Notice 13-27, and most recently amended by SR-FINRA-2015-019 effective November 2, 2015 as announced in Regulatory Notice 15-35 — which added paragraph (b)(7) requiring that decisions imposing permanent cease and desist orders include a statement consistent with FINRA Rule 9291(a)'s content, scope, and form requirements. Five selected notices are associated with the rule — 00-56, 08-57, 12-12, 13-27, and 15-35.

FINRA Rule 9268(a): The 60-Day Majority Decision

FINRA Rule 9268(a) establishes the decision drafting framework and its primary timeline. Within 60 days after the final date allowed for filing proposed findings of fact, conclusions of law, and post-hearing briefs pursuant to FINRA Rule 9266, the Hearing Officer shall prepare a written decision that reflects the views of the Hearing Panel or Extended Hearing Panel as determined by majority vote.

The 60-day decision drafting window begins running from the final post-hearing briefing date — the conclusion of the FINRA Rule 9266 briefing process, not the date of the hearing itself. The sequential timeline of FINRA Rule 9266's 60-day briefing window followed by FINRA Rule 9268's 60-day decision drafting window creates a total post-hearing period of up to 120 days from the conclusion of the hearing to the issuance of the Hearing Panel's decision under the default standards.

The Chief Hearing Officer has discretionary authority to establish a different date — acknowledging that complex multi-respondent cases may genuinely require more time and that straightforward cases may be resolved much faster.

The Hearing Officer prepares the written decision pursuant to FINRA Rule 9235(a)(7)'s authority — but the decision reflects the Panel majority's views as determined by collective deliberation and majority vote, not the Hearing Officer's individual analysis. The Hearing Officer is the draftsperson and the presiding officer; the Panel is the decision-maker. In a case where the Hearing Officer and one Panelist agree and the other Panelist dissents, the majority decision reflects the Hearing Officer and agreeing Panelist's conclusions, and the dissenting Panelist may write a separate dissenting opinion under FINRA Rule 9268(c).

FINRA Rule 9268(b): The Seven Required Content Elements

FINRA Rule 9268(b) specifies seven required content elements that every Hearing Panel decision must include. These requirements ensure that the decision is a complete, reasoned adjudicative document — not merely a pronouncement of outcome — that provides the respondent with a full explanation of the findings and conclusions against them and provides the foundation for meaningful appellate review.

The first required element — a statement describing the investigative or other origin of the disciplinary proceeding if not otherwise contained in the record — places the decision in institutional context. A reader of the decision who was not present for the proceedings should be able to understand from the decision itself how the disciplinary case began — whether from a routine examination, a customer complaint, a regulatory referral, a self-report, or other investigative source. This contextual statement is required only if not otherwise contained in the record, recognizing that some proceedings have a well-documented origin that is already part of the official record.

The second required element — the specific statutory or rule provisions that were alleged to have been violated — identifies the precise regulatory basis for the charges. A decision that does not clearly identify which rules were charged provides inadequate notice to the respondent and inadequate guidance to appellate bodies. The statutory or rule provisions statement must be specific enough to enable the respondent and appellate bodies to assess whether the charged provisions apply to the alleged conduct.

The third required element — a statement setting forth the findings of fact with respect to any act or practice the respondent was alleged to have committed or omitted — is the factual core of the decision. Every material factual finding must be stated, grounded in the evidence of record pursuant to FINRA Rule 9266(b)'s record citation requirement, and sufficiently detailed to enable the respondent to understand which specific alleged conduct was found to have occurred and which was not. The findings of fact are the foundation of appellate review — the NAC and SEC assess whether the findings are supported by substantial evidence in the record as a whole and whether they support the legal conclusions that follow.

The fourth required element — the conclusions of the Hearing Panel as to whether the respondent violated any provision alleged in the complaint — is the legal determination: guilty or not guilty on each charged cause of action. Every cause of action must be addressed — the decision must determine whether each charged rule was violated, not merely pronounce a global guilty or not guilty finding. A cause of action that is not addressed in the conclusions leaves the respondent and appellate bodies uncertain about the Panel's determination on that charge.

The fifth required element — a statement of the Hearing Panel in support of the disposition of the principal issues raised in the proceeding — is the analytical reasoning that explains the Panel's conclusions. The analytical support statement is the most intellectually demanding element of the required content — it must explain why the Panel found or did not find violations on the principal issues, engaging with the key legal and factual arguments raised by the parties. Published OHO decisions provide extensive examples of this analytical requirement — Hearing Panel decisions typically include multi-page analyses of the factual record, the applicable legal standards, and the application of those standards to the found facts.

The sixth required element — a statement describing any sanction imposed, the reasons therefor, and the date upon which the sanction shall become effective — addresses the penalties imposed for any violations found. Every sanction must be specifically described, grounded in the FINRA Sanction Guidelines' analytical framework, and assigned an effective date. The March 2024 Sanction Guidelines establish the framework within which Hearing Panels determine appropriate sanctions — aggravating and mitigating factors, principal considerations for each violation type, ranges of appropriate fines, and the factors supporting bars versus suspensions — and the FINRA Rule 9268(b)(6) reasons therefor requirement means that the sanction analysis must explain how the Guidelines were applied to the specific facts of the case.

The seventh required element — added by SR-FINRA-2015-019 effective November 2, 2015 — is a statement consistent with FINRA Rule 9291(a)'s content, scope, and form requirements when the sanctions include a permanent cease and desist order. FINRA Rule 9291(a) requires that a permanent cease and desist order specifically order the respondent to cease and desist from violating a specific rule or statutory provision, describe the conduct with reasonable specificity, and set forth the acts to be taken or refrained from. The 2015 amendment to FINRA Rule 9268 ensures that every decision imposing a PCDO complies with FINRA Rule 9291(a)'s requirements — preventing imprecise or overly broad PCDO language that would create enforcement uncertainty.

FINRA Rule 9268(c): The 65-Day Dissenting Opinion Window

FINRA Rule 9268(c) provides that within 65 days after the final post-hearing briefing date — five days longer than the majority decision window — the Hearing Officer or any Panelist may prepare a written dissenting opinion. The five additional days beyond the majority decision window accommodate the practical reality that a dissenting opinion is typically written in response to the majority's completed decision — the dissenter needs to see the majority's reasoning before crafting the most focused and effective dissent.

Dissenting opinions are a recognized and valued feature of FINRA's adjudicative system. Published OHO decisions include dissents on significant cases, and the existence of a principled dissent may strengthen a respondent's appellate arguments by identifying issues on which reasonable adjudicators disagree. A Panelist who would have found no violation, or who would have imposed a materially different sanction, may write a dissenting opinion explaining their view — creating a record of the principled disagreement that the NAC and SEC may find informative in appellate review.

FINRA Rule 9268(d): Service, Notice, and Dissemination

FINRA Rule 9268(d) establishes the dissemination obligations that ensure the Hearing Panel's decision reaches all relevant recipients promptly. OHO shall promptly serve the decision and any dissenting opinion on the parties pursuant to FINRA Rule 9132 — the Adjudicator-issued document service rule. OHO shall publish notice of the decision and any dissenting opinion in the Central Registration Depository — the CRD that underlies BrokerCheck and serves as the central repository of registration and disciplinary information about FINRA members and associated persons. And OHO shall provide a copy to each FINRA member with which a respondent is associated — ensuring that the respondent's current employer receives immediate notice of the disciplinary decision and can take appropriate supervisory action.

The CRD publication requirement connects FINRA Rule 9268 to FINRA Rule 8312's BrokerCheck disclosure framework — Hearing Panel decisions become part of the public record accessible through BrokerCheck upon CRD publication. The employer notification requirement serves the supervisory oversight function — a member firm employing a respondent who has been found to have violated FINRA rules and sanctioned must know about that decision to implement appropriate heightened supervision under FINRA Rule 9285 if applicable and under the firm's general supervisory obligations.

FINRA Rule 9268(e): Finality

FINRA Rule 9268(e) establishes the conditions under which a Hearing Panel decision becomes final disciplinary action of FINRA for purposes of SEA Rule 19d-1(c)(1) — the Exchange Act rule governing FINRA's obligation to report disciplinary actions to the SEC. The decision becomes final if not timely appealed pursuant to FINRA Rule 9311 or timely called for review pursuant to FINRA Rule 9312. The twenty-five-day appeal period under FINRA Rule 9311 runs from service of the Hearing Panel decision. If neither an appeal nor a call for review is filed within the applicable periods, the Hearing Panel's majority decision stands as FINRA's final disciplinary action.

The finality concept connects FINRA Rule 9268 to the entire downstream enforcement framework. A final disciplinary action triggers FINRA's SEA Rule 19d-1(c)(1) reporting obligation — FINRA must report the final action to the SEC. A final disciplinary action also triggers the sanctions effectiveness provisions of FINRA Rule 9268(f) — sanctions take effect only upon finality. And a final disciplinary action is the event from which FINRA's public disclosure obligations under FINRA Rule 8313 flow.

FINRA Rule 9268(f): Sanctions Effectiveness

FINRA Rule 9268(f) establishes the default sanctions effectiveness rules for decisions that have become final disciplinary action. Two distinct standards apply depending on the severity of the sanction.

For sanctions other than a bar or an expulsion — fines, suspensions, conditions, and other sanctions — the sanction becomes effective on a date to be determined by FINRA. This staff-determined effective date provides operational flexibility — FINRA can provide the respondent with a brief period to wind down activities, arrange for supervision, or otherwise prepare for the sanction before it takes effect, while ensuring that the sanction does become effective promptly after finality.

For bars and expulsions — the most severe sanctions — the sanction becomes effective immediately upon the decision becoming final disciplinary action of FINRA. The immediate effectiveness of bars and expulsions reflects the investor protection imperative — a person barred from the industry or a firm expelled from FINRA membership must cease their regulated activities the moment the decision is final, without any grace period that would allow continued harm to investors.

The unless otherwise provided in the majority decision qualifier preserves the Panel's ability to specify a different effective date in specific circumstances — for example, a delayed effective date for a sanction that would otherwise take effect during a particularly disruptive period for a firm's clients, or an immediate effective date for a non-bar sanction where investor protection concerns warrant expedited effectiveness.

The Automatic Stay for Appeals

FINRA Rule 9311 provides that an appeal to the NAC from a Hearing Panel decision issued under FINRA Rule 9268 operates as an automatic stay of that decision pending the NAC's ruling — the sanctions do not take effect while the appeal is pending. The one exception to this stay is a decision imposing a permanent cease and desist order, which is not stayed by an appeal under FINRA Rule 9311. This non-stay for PCDOs reflects the same investor protection logic as FINRA Rule 9268(f)'s immediate effectiveness rule for bars — the continuing conduct prohibited by a PCDO is sufficiently harmful that it cannot be permitted to continue during the appellate period.

Connection to FINRA Rules 9235, 9266, 9269, 9270, 9285, 9291, and 9311

FINRA Rule 9268 is the culmination of the entire disciplinary proceeding that the preceding rules in the 9260 subsection have structured. FINRA Rule 9235(a)(7)'s authority to draft the majority decision is exercised through FINRA Rule 9268(a). FINRA Rule 9266's post-hearing briefing process establishes the briefing date from which FINRA Rule 9268's 60-day and 65-day windows run. FINRA Rule 9269's default decision parallel is discussed below. FINRA Rule 9270's settlement procedure is an alternative to a FINRA Rule 9268 decision. FINRA Rule 9285's interim orders are imposed by the Hearing Officer after a FINRA Rule 9268 decision is appealed. FINRA Rule 9291's PCDO content requirements are cross-referenced in FINRA Rule 9268(b)(7). And FINRA Rule 9311's appeal right runs from service of the FINRA Rule 9268 decision.

Examination Relevance and Key Takeaways

FINRA Rule 9268 is tested on the Series 24 General Securities Principal examination as the Hearing Panel decision rule — one of the most practically important rules in the entire Code of Procedure covering the format, content, timing, dissemination, finality, and sanctions effectiveness of FINRA disciplinary decisions.

The key points to retain are these: FINRA Rule 9268(a) requires the Hearing Officer to prepare the majority decision within 60 days after the final post-hearing briefing date or by a Chief Hearing Officer discretionary date; the decision reflects the Hearing Panel majority's views as determined by majority vote; FINRA Rule 9268(b) requires seven specific content elements — the investigative origin, charged rule provisions, findings of fact, violation conclusions, analytical support for principal issues, sanction description with reasons and effective date, and for PCDOs a statement consistent with FINRA Rule 9291(a) requirements; FINRA Rule 9268(c) permits the Hearing Officer or any Panelist to prepare a written dissenting opinion within 65 days after the final briefing date; FINRA Rule 9268(d) requires OHO to promptly serve the decision on all parties, publish notice in the CRD, and provide copies to each FINRA member employing a respondent; FINRA Rule 9268(e) provides that an unappealed and uncalled-for-review decision becomes final disciplinary action of FINRA for SEA Rule 19d-1(c)(1) purposes; FINRA Rule 9268(f) provides that sanctions other than bars and expulsions become effective on a date FINRA determines while bars and expulsions become effective immediately upon finality; an appeal under FINRA Rule 9311 stays the Hearing Panel decision except for PCDOs which are not stayed; paragraph (b)(7) was added by SR-FINRA-2015-019 effective November 2, 2015; and the rule was last amended November 2, 2015 through SR-FINRA-2015-019 as announced in Regulatory Notice 15-35.