22 Exchanges Team Up Against Insider Trading—Regulatory Round-Robin
Published Date: 9/12/2025
Notice
Summary
The SEC just approved a fresh update to how 22 big stock exchanges and FINRA share the job of watching for insider trading. This means these groups will work together even better to catch and stop sneaky trading moves. The change kicks in right away and won’t cost anyone extra, but it makes the market safer and fairer for everyone.
Analyzed Economic Effects
5 provisions identified: 1 benefits, 3 costs, 1 mixed.
Quarterly fees for participating exchanges
FINRA will charge each Participating Organization a Quarterly Fee based on its Percentage of Publicly Reported Trades over three-month billing periods. If a participant's percentage is less than 1.0% the Quarterly Fee is $6,250; if between 1.0% and less than 2.0% the Quarterly Fee is $18,750; if 2.0% or greater the Quarterly Fee equals the participant's percentage multiplied by FINRA's Total Charge for the period.
Payment, default, and termination rules
A Participating Organization may cancel participation with 180 days' written notice and SEC approval. Participating Organizations have 30 days from invoice receipt to satisfy an invoice; after a Default notice they have another 30 days, and FINRA may terminate regulatory responsibilities for a Participating Organization that has Defaulted on payment more than three times in any rolling 24-month period.
FINRA will lead insider-trading oversight
FINRA will assume regulatory responsibility for surveillance, investigation, and enforcement of insider trading by broker-dealers that are Common FINRA Members with respect to NMS Stocks, effective the date the SEC declared the amendment effective (September 9, 2025). The Plan is intended to eliminate duplicate examinations and to protect the interest of investors by allocating these responsibilities to FINRA.
FINRA owns enforcement technology and IP
FINRA will remain the owner of its existing proprietary intellectual property used to perform the regulatory responsibilities (including the SONAR system) and will own any enhancements or newly developed intellectual property ("New IP"). FINRA will not charge Participating Organizations for New IP, but may charge fees for software maintenance on systems used to perform its duties.
Green Impact Exchange (GIX) added as participant
The September 4, 2025 amendment adds Green Impact Exchange, LLC (GIX) as a Participating Organization in the Plan; the amendment was declared effective by the SEC on September 9, 2025. As a Participating Organization, GIX is included within the Plan's allocation of regulatory responsibilities and the fee scheme set forth in Exhibit B.
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Key Dates
Department and Agencies
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