Regulatory Alerts2026-06-09 | Regulatory Notice 26-12Added · Updated
Guidance Regarding the Application of FINRA Rules in Relation to the SEC No-Action Letter on Personal Services Entities
FINRA clarifies how existing rules apply to the November 17, 2025 SEC no-action letter permitting registered representative-owned personal services entities to receive transaction-based compensation without broker-dealer registration. Broker-dealers must ensure all PSE owners and personnel are registered with the member, designate the PSE as a branch or OSJ, and maintain sole control over associated persons' securities activities. Members are required to update supervisory systems under Rule 3110, execute written servicing agreements, and maintain specific records regarding compensation payments and regulatory access. This guidance applies to arrangements entered into on or after November 17, 2025, and imposes no new obligations beyond the SEC letter's conditions.