The 2d Circuit held that the Financial Industry Regulatory Authority Inc. (FINRA) has no authority to bring court actions to collect disciplinary fines. FINRA, a self-regulatory organization (SRO), is "responsible for conducting investigations and commencing disciplinary proceedings against member firms." But the Securities Exchange Act of 1934 provides "no express statutory authority for SRO's to bring judicial actions to enforce the collection of fines." Therefore, while FINRA may impose a fine, it may not sue to collect it.