FINRA tweaks adviser order rules—SEC nods, world keeps turning.
Published Date: 9/8/2026
Notice
Summary
No summary available.
Analyzed Economic Effects
3 provisions identified: 3 benefits, 0 costs, 0 mixed.
No Principal Approval for IA Bulk Orders
The SEC approved a change to FINRA Rule 4515.01 that removes the rule’s timing requirement for principal approval of investment-adviser (IA) bulk orders. Previously members did not need principal approval only if allocation instructions were received by the end of the trade date; under the change the exception applies to all IA bulk orders regardless of when allocation instructions are received. The order was approved September 2, 2026.
Applies to DVP/RVP and Prime Brokers
FINRA clarified the rule change applies to delivery-versus-payment (DVP) and receive-versus-payment (RVP) arrangements and to prime brokers that receive allocation instructions directly from an investment adviser. Those specific arrangements are covered by the expanded exception from the principal-approval timing requirement.
Investor Protections Remain in Place
The Commission noted several safeguards remain after approval, including Exchange Act Rules 15c6-2(a) and 17Ad-27, Section 206 of the Investment Advisers Act, and FINRA Rules 4515.01, 2010, and 3110. These rules require written agreements, policies, monitoring, and prohibit fraudulent or deceptive allocation practices.
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