What is required before an eligibility proceeding may be put through expedited review?

A determination by the Executive Committee alone, the Committee's recommended decision being before it

A request from the Statutory Disqualification Committee and a determination by the Executive Committee

A request from the Department of Member Regulation, which the Executive Committee must then accept

A call for review by any Governor, expedited handling following automatically from an early call

The standard for directing expedited review is that it be necessary for the protection of investors. What does that standard exclude?

Matters in which the disqualified person is currently dealing with customers of the sponsoring firm

Matters the Statutory Disqualification Committee has recommended be denied rather than granted

Matters that are merely important or significant, where the ordinary timeline creates no harm itself

Matters already the subject of a Commission proceeding arising from the same disqualifying conduct

Expedited review has been directed. How long does a Governor then have to call the proceeding for review, and from when?

Seven days from receipt of the recommended written decision

Until the next Board meeting falling at least seven days after the recommended decision is received

Fifteen days from receipt, the ordinary period being unaffected by the direction to expedite

Fourteen days from the direction to expedite rather than from receipt of the decision

No Governor calls an expedited eligibility proceeding for review within the period allowed. Whose decision then stands as FINRA's final action?

The Executive Committee's, which directed the expedited review and therefore disposes of it

The Statutory Disqualification Committee's recommended decision, which becomes final as it stands

The Board's, a decision becoming final only when the full Board has declined to intervene

The National Adjudicatory Council's, which must still adopt the recommendation before it is final

When no Governor calls an expedited eligibility proceeding for review, the decision that becomes final, a denial included, takes effect upon Commission approval. When does a decision to approve take effect under the standard eligibility review framework of FINRA Rule 9525, by contrast?

When it is served on the parties, a standard decision to approve needing no further step by the Commission

At once on becoming FINRA's final action, the Commission's role being limited to any later application for review

After the Commission issues an acknowledgment letter, or an order where Commission-ordered sanctions are involved

Once the fifteen-day period for a Governor's call has passed without any Governor calling it for review

A Governor calls an expedited eligibility proceeding for review. By when must the review panel meet and review it?

At the next meeting of the FINRA Board, as in an ordinary call for review

Not later than seven days after the call, matching the period in which the call was made

Within a reasonable time, the panel fixing its own timetable once it has been constituted

An Industry Governor calls an expedited proceeding for review. How is the review panel then constituted?

The Executive Committee, with the calling Governor replacing an Industry member of that committee

The Executive Committee with the calling Governor added, enlarging the panel by one member

A panel drawn from the Statutory Disqualification Committee, the Executive Committee having already acted

The Executive Committee sits as it stands, the calling Governor taking no part in the review

The Executive Committee has directed expedited review in an eligibility proceeding. How does the expedited framework relate to the standard review procedures that would otherwise govern the matter?

It runs alongside them, shortening their deadlines while every step of the ordinary route is still taken in turn

It operates notwithstanding them, their ordinary timelines yielding to its compressed ones

It overrides them only for the call-for-review period, the review itself still waiting for the next Board meeting

It suspends them until the Commission approves the direction to expedite

The Statutory Disqualification Committee has four eligibility matters before it. For which of them may expedited review be warranted?

An application raises a novel legal question, and the recommended decision may set a precedent for later matters

A prominent individual is joining a large firm, and the recommended decision is likely to attract press attention

A disqualified person is actively dealing with investors, and the recommended decision raises immediate concerns

An application is routine, and the sponsoring firm has asked for the recommended decision to be finalised quickly

Expedited review has been directed in an eligibility proceeding. The recommended written decision was received on Monday 1 March, and the Executive Committee made its direction on Wednesday 3 March. No Federal holiday falls in the weeks that follow. A Governor calls the proceeding for review on Thursday 11 March. Is the call in time?

No — and the recommended decision therefore passes to the National Adjudicatory Council to decide

Yes — the period runs from the Executive Committee's direction to expedite, so it closes on Friday 12 March

Yes — a Governor's call is timely at any point before a review panel has been constituted

No — the period runs from receipt of the recommended decision, and it closed on Wednesday 10 March

When expedited review is directed, the period in which a Governor may call an eligibility proceeding for review is shortened. What two needs does the shorter period balance?

Time for Governors to assess the recommended decision, and speed in meeting the investor-protection concern

Time for the parties to file written submissions, and speed in obtaining the Commission's approval

Time for the Executive Committee to reconsider its direction, and speed in convening the review panel

Time for the sponsoring member to adjust its supervisory plan, and speed in serving the final decision

No Governor calls an expedited eligibility proceeding for review within the period allowed. Who then serves the decision, and on whom?

The Executive Committee serves it, on the parties and on every Governor of the FINRA Board

The Statutory Disqualification Committee serves it, on the parties and the Department of Member Regulation

The Office of Hearing Officers serves it, on the parties alone, the department having no role

The Department of Member Regulation serves it, on the parties and the sponsoring member's principal

An expedited eligibility decision that becomes FINRA's final action without a call for review takes effect only once the Commission approves it. What does the Commission-approval requirement reflect?

The Department of Member Regulation's need for Commission sign-off before it may act on any final eligibility decision

The Commission's supervision of the Executive Committee, whose directions to expedite it must ratify before they operate

Coordination with the Commission's own oversight of statutory disqualification, under which it approves certain eligibility determinations

The Commission's role in fixing the timetables for FINRA's eligibility proceedings, which the expedited route departs from

A Governor has called an expedited eligibility proceeding for review, and the review panel has conducted its review. What may the panel do with the Statutory Disqualification Committee's recommended written decision?

Modify, reverse or affirm it, though never remand it, the compressed timetable leaving no room to send it back

Affirm or reverse it only, any modification requiring a remand to the Committee

Affirm it or remand it, a reversal being reserved to the full FINRA Board

Affirm, modify or reverse it, or remand the proceeding with instructions

A Public Governor calls an expedited eligibility proceeding for review. Whose seat on the review panel does that Governor take?

That of a Public member of the Executive Committee, the panel's classification balance being kept

That of an Industry member of the Executive Committee, Industry seats always giving way to a caller

That of the Executive Committee's chair, the calling Governor presiding over the review

That of whichever Executive Committee member the chair selects, whatever that member's classification

The Statutory Disqualification Committee asks for expedited review of its recommended decision in an eligibility proceeding, but the Executive Committee does not determine that expedited review is necessary for the protection of investors. What happens to the proceeding?

It is expedited anyway, the Committee's request being enough to trigger it once the request is made

It continues through the standard process, with the ordinary fifteen-day period for a Governor's call

It is referred to the full FINRA Board, which decides afresh whether it should be expedited

It is suspended until the Committee renews its request with fresh evidence of the urgency

A review panel has decided an expedited eligibility proceeding that a Governor called for review. What must the panel's written decision contain?

A statement of the investor-protection urgency, in place of the findings a standard decision contains

Only the panel's disposition and the date it takes effect, the expedited route dispensing with reasons

The same content elements required of a standard Council or Board decision in an eligibility proceeding

Whatever content the Executive Committee specified when it directed expedited review of the matter

An expedited eligibility decision has become FINRA's final action because no Governor called it for review. May a party still apply to the Commission for review of it?

Yes — though the application goes first to the Executive Committee, which decides whether to forward it

No — the Commission's approval of the decision takes the place of any application for its review

No — an application for review lies only from a decision that the National Adjudicatory Council has made

Yes — the right to apply for Commission review follows any final eligibility action, expedited ones included

In an expedited eligibility proceeding, a Governor calls the proceeding for review on Monday the 1st of a month. No Federal holiday falls in the following three weeks. The review panel first meets on Wednesday the 17th. Did it meet within the time allowed?

No; the weekends that fall inside the period are counted, so the period had already run out

Yes; the weekends that fall inside the period are left out of the count, so it was still running

Yes; the period starts only once the panel has been constituted, not on the day of the call itself

No; a called proceeding must be reviewed by the next Board meeting, whatever the panel's own timetable

A sponsoring member applied to associate a disqualified person, and expedited review was directed. No Governor calls the proceeding for review within the period allowed. Besides the sponsoring member, who is among the persons on whom the resulting final decision is served?

Each Governor of the FINRA Board, none of whom called the proceeding for review in time

The disqualified person whose association the sponsoring member applied for

The Executive Committee, which directed the expedited review of the Committee's recommendation

The firm that last employed the disqualified person before the disqualifying event occurred

FINRA staff initiated an eligibility proceeding, and the sponsoring member then applied. After a call for expedited review, the sponsoring member's counsel privately e-mails a member of the review panel, arguing that the recommended decision should be affirmed. What must the panel member do with the e-mail?

Delete it unread, so that nothing in it can reach the panel's deliberations

Withdraw from the panel and leave the review to its remaining members

Forward it to the Department of Member Regulation to decide whether to answer it

In an expedited eligibility proceeding, an employee of the Department of Member Regulation, which acts as a Party in the proceeding, offers to advise the review panel on what decision to reach. May the employee do so?

No; the department's staff may take part only as counsel or as witnesses, not by advising the panel

Yes, but only where the employee personally had no part in assessing this particular application

Yes; the department assessed the application, and the panel is expected to hear its view privately

No; nobody from the department may take any part in the review, even as a witness or counsel

A Party's counsel privately contacts one member of the review panel in an expedited eligibility proceeding. Under the Code's definitions, why can the ex parte prohibition reach that individual member and not only the panel as a body?

The prohibition reaches every Governor of the FINRA Board in every proceeding under the Code, whatever role each holds

A natural person serving on a body that presides over a proceeding and decides it is an Adjudicator

Counsel to a Party is barred from contacting any FINRA official at all, whether or not that official decides the case

Every member of a review panel becomes Interested FINRA Staff from the moment the panel has been constituted

A Public Governor who is neither the Chair of the FINRA Board nor a member of the National Adjudicatory Council calls an expedited eligibility proceeding for review and sits on the review panel. A party then contends that this Governor has a conflict of interest in the matter. Who has authority to order the Governor's disqualification?

The Chair of the National Adjudicatory Council, whose authority reaches the Statutory Disqualification Committee in the same proceeding

A majority of the FINRA Board, excluding the challenged Governor, voting on the party's contention

The Chair of the FINRA Board, the calling Governor being a member of FINRA's Board of Governors

The other members of the review panel, deciding the party's contention by a majority vote

A member of the review panel in an expedited eligibility proceeding is about to take part in its review. The member has no conflict of interest and no bias, but circumstances exist in which the member's fairness might reasonably be questioned. May the member take part in the review?

Yes — stepping aside is required where a conflict of interest or a bias is shown, and neither exists here

Yes — unless a party moves for disqualification and proves that the member is actually biased against it

Yes, provided both parties consent on the record to the member continuing to sit on the panel

No — that ground by itself requires the member to recuse himself or herself or be disqualified

FINRA staff initiated an eligibility proceeding and the sponsoring member then applied. During an expedited review, the sponsoring member's counsel e-mails a member of the review panel to argue the merits, sending the Department of Member Regulation a copy at the same time and inviting it to respond. Does FINRA Rule 9143(a)(1) bar that communication?

No — the bar is aimed at ex parte communications, and one made on notice with an opportunity for all Parties to participate falls within the exception

Yes — the bar turns on the subject matter of the message alone, so copying the other Party leaves a merits argument to a panel member prohibited

Yes — a merits communication to a panel member is barred unless the review panel itself has first invited counsel to write to it

No — but only once the Department has actually replied, the exception depending on the other Party taking part in the exchange

No Governor calls an expedited eligibility proceeding for review within the period allowed. The Statutory Disqualification Committee proposes to serve the resulting final decision on the sponsoring member by uploading it to the OHO Portal. Would that upload be a method of service the rules provide for this decision?

Yes — the October 2025 amendment brought FINRA Rule 9526 into the OHO Portal package, making upload the standard way for the Committee to serve the decisions it issues

No — the decision is served under paragraphs (a) and (b) of FINRA Rule 9134 or by e-mail, and Portal service is confined to proceedings before the Office of Hearing Officers

Yes — upload is available for any decision served pursuant to FINRA Rule 9134, the Portal being one of the methods that rule offers to every body serving under the Code

No — a decision that becomes final without a call may be served only by electronic mail, that being the one method FINRA Rule 9132(b) leaves open to the Committee

Where a hearing was requested in an eligibility proceeding, what does the Statutory Disqualification Committee consider before presenting the recommended written decision that expedited review under FINRA Rule 9526 examines?

The record of the proceeding alone, a Hearing Panel in an eligibility proceeding making findings of fact but no recommendation

The Hearing Panel's recommended decision and the National Adjudicatory Council's proposed written decision on the same application

The record of the proceeding and the Hearing Panel's recommended decision, which the Hearing Panel presents to it in writing

The Department of Member Regulation's recommendation, the Hearing Panel's part in the proceeding ending when the hearing closes

No Governor calls an expedited eligibility proceeding for review within the period allowed. The Statutory Disqualification Committee sends the resulting final decision to the sponsoring member by courier on a Tuesday, and the courier delivers it on the Thursday. On which day is service on the sponsoring member complete?

Tuesday, service by courier being complete when the decision is handed to the courier, as service by mail is complete on posting

Wednesday, service by courier being complete on the business day after dispatch, whatever day the courier in fact delivers

Thursday, provided the sponsoring member signs for the decision, service by courier being incomplete until receipt is acknowledged

Thursday, service by courier being complete upon delivery to the sponsoring member rather than when the decision is sent

FINRA Rule 9526 | Financial Regulation Courses

Expedited Review

SERIES 24 | FINANCIAL REGULATION COURSES

FINRA Rule 9526 governs the expedited review mechanism available in eligibility proceedings when the FINRA Board Executive Committee determines that investor protection urgency warrants accelerating the standard Board review timeline.

The rule establishes four operative provisions: the Executive Committee's authority to direct expedited review upon request of the Statutory Disqualification Committee when investor protection requires it; a compressed seven-day Governor call-for-review period applicable when expedited review has been directed; the finality and service consequences when no Governor calls the expedited proceeding for review within that compressed period; and the composition, timeline, and dispositional authority of the review panel that convenes when a Governor does call the proceeding for review within the seven-day window.

FINRA Rule 9526 is structurally positioned as an exception to the normal FINRA Rules 9524 and 9525 framework — it can be invoked notwithstanding those rules' standard processes — reflecting the reality that certain eligibility determinations involve sufficient investor protection urgency to warrant faster resolution than the standard fifteen-day Board review period allows.

FINRA Rule 9526 sits within the 9520 Eligibility Proceedings series of the 9500 Other Proceedings section of the 9000 Code of Procedure. It was adopted by SR-NASD-98-57 effective March 26, 1999 — added to the Rule 9520 series along with expedited review provisions announced in Notice to Members 99-16 — amended by SR-NASD-99-76 effective September 11, 2000, amended by SR-FINRA-2008-021 effective December 15, 2008, and most recently amended by SR-FINRA-2025-013 effective October 7, 2025 as announced in Regulatory Notice 25-10 — the OHO Portal implementation amendment that made conforming updates across the Code of Procedure. Four selected notices are associated — 99-16, 00-56, 08-57, and 25-10.

FINRA Rule 9526(a): The Executive Committee's Expedited Review Direction

FINRA Rule 9526(a) establishes the threshold requirement for invoking the expedited review mechanism: the FINRA Board Executive Committee, upon request of the Statutory Disqualification Committee, may direct an expedited review of a recommended written decision of the Statutory Disqualification Committee if the Executive Committee determines that expedited review is necessary for the protection of investors.

Three features of this authority are operationally significant. First, the invocation requires both a request from the SD Committee and a determination by the Executive Committee — neither body can trigger expedited review unilaterally. The SD Committee's request reflects its assessment that the specific eligibility matter presents investor protection urgency warranting accelerated Board review. The Executive Committee's determination is an independent assessment of whether that urgency justifies bypassing the standard FINRA Rule 9525 fifteen-day review period in favor of the compressed FINRA Rule 9526 seven-day period.

Second, the notwithstanding FINRA Rules 9524 and 9525 formulation confirms that FINRA Rule 9526's expedited mechanism operates as an override of the standard processes — when expedited review is directed, the normal procedural timelines of those rules yield to FINRA Rule 9526's compressed framework.

Third, the necessary for the protection of investors standard is deliberately demanding. Expedited review is an extraordinary mechanism reserved for situations where the normal Board review timeline would itself create or allow investor harm — not a convenience mechanism for cases that are simply important or significant. A situation where an eligibility decision affects a disqualified person who is actively interacting with investors and where the SD Committee's recommended decision raises immediate concerns may warrant expedited review. A routine application involving modest investor protection concerns does not.

FINRA Rule 9526(b): The Seven-Day Call-for-Review Period

When the Executive Committee directs expedited review of a recommended written decision, the standard fifteen-day Governor call-for-review period of FINRA Rule 9525 is replaced by a seven-day period. A Governor may call the eligibility proceeding for review within seven days after receipt of the recommended written decision.

The compression from fifteen days to seven days is the operational heart of the expedited review mechanism. The standard fifteen-day minimum ensures that Governors have adequate time to review complex eligibility applications before deciding whether to call them for Board review. In the expedited context — where the Executive Committee has already determined that investor protection urgency is present — the compressed seven-day period reflects the balance between providing Governors enough time to assess the recommended decision and moving quickly enough to address the investor protection concern that triggered expedited review in the first place.

FINRA Rule 9526(c): No Call for Review — Finality and SEC Approval

When no Governor calls the expedited proceeding for review within the seven-day period, FINRA Rule 9526(c) establishes a distinctive finality framework that differs from the standard FINRA Rule 9525 framework in one critically important respect. The decision shall become final, and the Statutory Disqualification Committee shall serve the decision on the parties and the Department of Member Regulation pursuant to FINRA Rule 9132 and paragraphs (a) and (b) of FINRA Rule 9134. The decision shall constitute final action of FINRA. However, the decision shall be effective upon approval by the SEC.

The SEC approval requirement is the defining feature of FINRA Rule 9526(c). Under the standard FINRA Rule 9525 finality framework, a decision to approve is effective after the SEC issues an acknowledgment letter or, in cases involving SEC-ordered sanctions, an order; under FINRA Rule 9526(c), every decision that becomes final because no Governor calls it for review, a denial included, is effective upon approval by the SEC. Eligibility decisions that become final in this way are not immediately operative; they must be approved by the SEC before they take effect. This SEC approval requirement reflects the fact that FINRA's eligibility proceedings operate in coordination with the SEC's statutory disqualification oversight framework under Exchange Act Section 15(b) and SEA Rule 19h-1. The SEC must approve FINRA's eligibility determinations in certain categories of cases as part of the broader federal regulatory framework governing who may participate in the securities industry.

The SEC approval requirement effectively means that an expedited FINRA eligibility decision — even one that has become final as a FINRA matter — does not permit the disqualified person to begin or continue their association until the SEC has reviewed and approved the determination. This creates a brief additional waiting period between FINRA's final action and the person's ability to act on the approval, which operates as a further investor protection measure in the expedited context.

FINRA Rule 9526(d): Call for Review — The Review Panel

When a Governor calls the expedited eligibility proceeding for review within the seven-day period, FINRA Rule 9526(d) establishes the composition, timeline, and dispositional authority of the review panel that conducts the review.

The timeline is compressed to match the expedited urgency: a review panel shall meet and conduct a review not later than fourteen days after the call for review. The fourteen-day hearing window is significantly faster than the standard Board review timeline of the next Board meeting following the call.

The review panel composition reflects both the expedited character of the proceeding and the governance structure of the FINRA Board. The review panel shall be composed of the FINRA Board Executive Committee, except that the Governor who calls the proceeding for review shall serve on the review panel in lieu of a member of the Executive Committee who has the same classification — Industry or Public — as the calling Governor. This substitution mechanism ensures two things: the calling Governor participates in the review they triggered, and the review panel maintains the same Industry/Public composition balance as the Executive Committee would otherwise provide. A calling Governor who is an Industry member replaces an Industry Executive Committee member; a calling Governor who is a Public member replaces a Public Executive Committee member.

The review panel's dispositional authority mirrors FINRA Rule 9525's Board dispositional authority: the review panel may affirm, modify, or reverse the recommended written decision of the Statutory Disqualification Committee or remand the eligibility proceeding with instructions. The review panel shall prepare, issue, and serve its decision pursuant to FINRA Rule 9525(d) and (e) — adopting the standard Board decision content, service, and finality provisions of FINRA Rule 9525 for the expedited review panel's output.

The October 2025 Amendment

The most recent amendment to FINRA Rule 9526 — SR-FINRA-2025-013 effective October 7, 2025 as announced in Regulatory Notice 25-10 — made conforming updates to FINRA Rule 9526 as part of the broader OHO Portal implementation package. While the substantive framework of FINRA Rule 9526 was not materially changed by this amendment, the conforming updates were made as part of that implementation; FINRA Rule 9526(c) itself provides for service pursuant to paragraphs (a) and (b) of FINRA Rule 9134, not under the Portal provisions of paragraph (c).

FINRA Rule 9526 in the Context of Eligibility Proceedings Architecture

FINRA Rule 9526 occupies a distinctive position in the Rule 9520 series architecture. It is not a routine step in every eligibility proceeding — the vast majority of eligibility applications proceed through FINRA Rules 9522, 9523, 9524, and 9525 without the Executive Committee ever invoking FINRA Rule 9526's expedited review mechanism. FINRA Rule 9526 exists for the rare situation where the normal governance timeline is itself an investor protection problem — where a specific eligibility determination is sufficiently urgent that the standard fifteen-day Board review period is inadequate.

The practical rarity of FINRA Rule 9526 invocations reflects both the demanding investor-protection-necessity standard and the fact that most eligibility proceedings do not present the kind of immediate urgency that expedited review addresses. When it is invoked, however, FINRA Rule 9526 provides a complete, legally sound expedited review mechanism that maintains all the essential governance safeguards — Governor call-for-review right, review panel composition balance, full dispositional authority, SEC approval requirement — while compressing the timeline to address urgent situations.

Connection to FINRA Rules 9524, 9525, and 9527

FINRA Rule 9526 connects to FINRA Rules 9524 and 9525 as the rules it operates notwithstanding — when expedited review is directed, FINRA Rule 9526's compressed timelines override those rules' standard processes. It connects to FINRA Rule 9524(b)(2) through FINRA Rule 9525(d) and (e)'s cross-reference — the review panel's written decision must include the same content elements required of standard NAC and Board eligibility decisions. And it connects to FINRA Rule 9527 — whose SEC review application right is available following any final FINRA eligibility action, including decisions that become final through the FINRA Rule 9526 expedited process after the seven-day period without a Governor call.

Counting the Seven-Day Call Period

FINRA Rule 9526(b) gives a Governor seven days after receipt of the recommended written decision to call an expedited eligibility proceeding for review. FINRA Rule 9138 sets the formula for computing any period of time designated in the Code. Under FINRA Rule 9138(a), "day" in the Rule 9000 Series means calendar day. Under FINRA Rule 9138(b), the day of the act or event from which the period begins to run is not included. The last day is included unless it is a Saturday, Sunday or Federal holiday, in which event the period runs until the end of the next day that is not a Saturday, Sunday or Federal holiday. Intermediate Saturdays, Sundays and Federal holidays are excluded from the computation when the period prescribed is ten days or less.

The seven-day call period is ten days or less, so the weekends that fall inside it are left out of the count. Suppose the recommended written decision is received on Thursday the 3rd of a month, and no Federal holiday falls in the following two weeks. Thursday the 3rd is not counted, so Friday the 4th is the first day. Saturday the 5th and Sunday the 6th are excluded. Monday the 7th to Friday the 11th are days two to six. Saturday the 12th and Sunday the 13th are excluded, and Monday the 14th is the seventh day. A Governor's call made on Monday the 14th is within the period, even though it comes eleven calendar days after receipt.

Some expedited proceedings elsewhere in the Code count their short periods straight through. FINRA Rule 9559(b) includes intermediate Saturdays, Sundays and Federal holidays in the computation, but only in proceedings brought under FINRA Rules 9556 through 9558 and 9561 of the Rule 9550 Series. Expedited review under FINRA Rule 9526 belongs to the Rule 9520 Series, so that modification does not apply to the seven-day call period.

Counting the Review Panel's Fourteen Days

The same rule counts the fourteen days within which a review panel must meet and conduct its review under FINRA Rule 9526(d). That period is longer than ten days, so intermediate Saturdays and Sundays are counted. Suppose a Governor calls the proceeding for review on Monday the 1st of a month, and no Federal holiday falls in the following three weeks. The day of the call is not counted, so the fourteenth day is Monday the 15th. A review panel that first meets on Wednesday the 17th has met outside the period, even though only twelve weekdays have passed since the call.

The last-day rule also applies to the fourteen days. Where the fourteenth day after the call is a Saturday, a Sunday or a Federal holiday, the period runs until the end of the next day that is not a Saturday, Sunday or Federal holiday. So if Monday the 15th in the example were a Federal holiday, a review panel meeting on Tuesday the 16th would be within the period.

Serving a Decision That Becomes Final Without a Call

FINRA Rule 9526(c) names who is served when a decision becomes final because no Governor called it: the disqualified member, sponsoring member, and/or disqualified person, as the case may be, and the Department of Member Regulation. FINRA Rule 9521(b) defines the first three. A disqualified person is an associated person, or a person seeking to become one, who is or becomes subject to a disqualification or is otherwise ineligible for association. A sponsoring member is the member, or applicant for membership, sponsoring that person's association or continued association. So where a sponsoring member applied to associate a disqualified person, the persons named for service include the disqualified person as well as the sponsoring member.

FINRA Rule 9526(c) has the decision served pursuant to FINRA Rule 9132 and paragraphs (a) and (b) of FINRA Rule 9134. FINRA Rule 9120(a) names the Statutory Disqualification Committee as an Adjudicator. Under FINRA Rule 9132(b), an order, notice or decision issued by an Adjudicator other than a Hearing Officer, Hearing Panel or Extended Hearing Panel is served pursuant to paragraphs (a) and (b) of FINRA Rule 9134 or by electronic mail. The methods in FINRA Rule 9134(a) are personal service, service by U.S. Postal Service mail and service by courier. Service through the OHO Portal is provided for in paragraph (c) of FINRA Rule 9134, which FINRA Rule 9526(c) does not cite. FINRA Rule 9134(c)(3) also confines Portal service to proceedings before the Office of Hearing Officers.

FINRA Rule 9134(b)(3) fixes when service is complete. Personal service and service by courier are complete upon delivery, and service by mail is complete upon mailing. FINRA Rule 9132(b) makes service by electronic mail complete upon sending. Suppose the decision is sent to the sponsoring member by courier on a Tuesday and delivered on the Thursday. Service on the sponsoring member is complete on the Thursday. Had the same decision gone by first-class mail on the Tuesday, service would have been complete on the Tuesday.

The Review Panel's Own Decision

When a Governor has called the proceeding for review, FINRA Rule 9526(d) gives the decision to the review panel to prepare, issue and serve, pursuant to FINRA Rule 9525(d) and (e). FINRA Rule 9525(e), to which FINRA Rule 9526(d) refers, has the written decision issued and served on the disqualified member, sponsoring member and disqualified person, as the case may be, and the Department of Member Regulation, and allows service on the disqualified party by electronic mail.

FINRA Rule 9525(e) also provides that the decision constitutes the final action of FINRA unless the proceeding is remanded. Under FINRA Rule 9527, the right to have action taken under the Rule 9520 Series reviewed by the SEC is governed by Section 19 of the Exchange Act. Read with FINRA Rule 9526(d), which has the review panel prepare, issue and serve its decision pursuant to FINRA Rule 9525(d) and (e), a decision that affirms, modifies or reverses the Statutory Disqualification Committee's recommended decision is FINRA's final action. A decision that remands the eligibility proceeding with instructions is not.

Supervision While Expedited Review Is Pending

Where an application filed under FINRA Rule 9522(a)(3) or (b)(1)(B) seeks the continued association of a disqualified person, FINRA Rule 9522(f)(1) requires it to include an interim plan of heightened supervision. That plan must be in effect throughout the entirety of the application review process. The process is considered concluded only upon the final resolution of the eligibility proceeding. Under FINRA Rule 9526(c), the recommended decision becomes final when no Governor calls the proceeding for review within the time prescribed.

Suppose a firm's application to continue associating a disqualified representative includes an interim plan. The Statutory Disqualification Committee recommends approving the application, and the Executive Committee directs expedited review. While the seven-day call period is running, the proceeding has not been finally resolved. The favourable recommendation does not end the interim plan, which stays in effect.

Contact With the Review Panel

FINRA Rule 9120(a) defines an Adjudicator. It includes a body, board, committee or group that presides over a proceeding and renders a decision, and a natural person who serves on such a body. A review panel under FINRA Rule 9526(d) meets, conducts the review and may affirm, modify, reverse or remand, which fits the first of those descriptions; each of its members is then a natural person serving on such a body. In the Rule 9520 Series, FINRA Rule 9522(d) makes FINRA Rule 9143's ex parte prohibitions effective when FINRA staff has initiated the eligibility proceeding and knows that a member intends to file an application.

Under FINRA Rule 9143(a)(1), no Party, or counsel to or representative of a Party, may make an ex parte communication relevant to the merits of a proceeding to an Adjudicator who is participating in the decision. The exception is a communication made on notice and with opportunity for all Parties to participate. In the Rule 9520 Series, a member that is the subject of a notice or files an application under FINRA Rule 9522 is a Party. Suppose FINRA staff issued the notice and the sponsoring member then applied. The sponsoring member's counsel may not privately e-mail a member of the review panel arguing that the recommended decision should be affirmed. A panel member who receives such a communication must place it in the record of the proceeding.

A separate rule keeps FINRA's own staff on the other side out of the decision. FINRA Rule 9144(a) prohibits Interested FINRA Staff from advising an Adjudicator regarding a decision or otherwise participating in a decision of an Adjudicator, except as counsel or a witness. In a Rule 9520 Series proceeding, Interested FINRA Staff includes the head of the department designated as a Party and any FINRA employee who reports to that person. FINRA Rule 9524(a)(3)(B) provides that the Department of Member Regulation shall act as a Party in the eligibility proceeding. Read together, these provisions bar an employee of the Department of Member Regulation, other than as counsel or a witness, from advising the review panel regarding its decision.

Where Expedited Review Falls in the Proceeding

FINRA Rule 9524(a)(10) sets the order of the recommendations. The Hearing Panel presents a recommended decision in writing to the Statutory Disqualification Committee. After considering the record and that recommendation, the Statutory Disqualification Committee presents its own recommended decision in writing. FINRA Rule 9526(a) directs expedited review of a recommended written decision of the Statutory Disqualification Committee. So where a hearing was requested, the recommended decision that expedited review examines is one the Statutory Disqualification Committee presents after considering the record and the Hearing Panel's recommendation.

Recusal and Disqualification on the Review Panel

FINRA Rule 9160 provides that no person shall participate as an Adjudicator in a matter governed by the Code as to which he or she has a conflict of interest or bias, or where circumstances otherwise exist in which his or her fairness might reasonably be questioned. In any such case the person shall recuse himself or herself, or shall be disqualified. The three grounds are joined by "or", so any one of them is enough. A member of a review panel under FINRA Rule 9526(d) who has no conflict of interest and no bias still may not participate where circumstances exist in which his or her fairness might reasonably be questioned, and shall recuse himself or herself or be disqualified.

FINRA Rule 9160 then sets out who orders a disqualification, according to the kind of Adjudicator. Under FINRA Rule 9160(a), the Chair of the FINRA Board has authority to order the disqualification of a Governor. A majority of the FINRA Board, excluding the Chair, has authority to order the disqualification of the Chair. Under FINRA Rule 9120(p), a Governor is a member of the Board of Governors of FINRA. Under FINRA Rule 9526(d), the Governor who calls an expedited eligibility proceeding for review serves on the review panel.

Other bodies in the same eligibility proceeding fall under a different paragraph. Under FINRA Rule 9160(b), the Chair of the National Adjudicatory Council has authority to order the disqualification of, among others, a Hearing Panel appointed pursuant to the Rule 9520 Series, and the Statutory Disqualification Committee. Suppose a Public Governor calls an expedited eligibility proceeding for review. That Governor is not the Chair of the FINRA Board and is not a member of the National Adjudicatory Council. A party then contends that the Governor, now serving on the review panel, has a conflict of interest. FINRA Rule 9160(a) gives the Chair of the FINRA Board authority to order that Governor's disqualification.

Examination Relevance and Key Takeaways

FINRA Rule 9526 is tested on the Series 24 General Securities Principal examination as the expedited review rule for eligibility proceedings — the emergency mechanism available when investor protection urgency warrants compressing the standard Board review timeline.

The key points to retain are these: FINRA Rule 9526 provides an expedited review mechanism for eligibility proceedings that operates notwithstanding FINRA Rules 9524 and 9525; it is triggered by the FINRA Board Executive Committee upon request of the Statutory Disqualification Committee when the Executive Committee determines expedited review is necessary for the protection of investors; when expedited review is directed the standard fifteen-day Governor call-for-review period is replaced by a seven-day period measured from receipt of the recommended written decision; if no Governor calls the proceeding within seven days the decision becomes final FINRA action but is effective only upon approval by the SEC — distinguishing this finality framework from standard FINRA Rule 9525 finality; if a Governor calls within seven days a review panel composed of the FINRA Board Executive Committee — with the calling Governor substituting for an Executive Committee member of the same Industry or Public classification — must meet and conduct the review within fourteen days after the call; the review panel may affirm, modify, reverse, or remand and must prepare its decision pursuant to FINRA Rule 9525(d) and (e); the SEC approval requirement for decisions finalized without a Governor call is the most distinctive feature of FINRA Rule 9526's finality framework; and the rule was last amended October 7, 2025 through SR-FINRA-2025-013 as announced in Regulatory Notice 25-10.