The National Adjudicatory Council, the appellate tribunal for disciplinary cases of the Financial Industry Regulatory Authority, has increased the severity of potential sanctions FINRA adjudicators should consider for members who have been found to have engaged in misrepresentations or violated FINRA’s suitability requirements. Among other matters, adjudicators should now “strongly consider” barring an individual where there has been a finding of fraud, misrepresentation or material omissions of fact, rather than solely “considering” a bar, absent mitigating factors. Likewise, for intentional or reckless fraud by a firm, an adjudicator should now “strongly consider” expelling a firm from FINRA membership “where aggravating factors predominate the firm’s misconduct.” An individual should be suspended from 31 calendar days to two years for negligent misrepresentations or material omissions of fact, says NAC. In general, NAC recommends that sanctions in disciplinary cases “should be significant enough to achieve deterrence, and not a mere cost of doing business.”