The Financial Industry Regulatory Authority (FINRA) published a notice on November 28 outlining a number of factors that it claims it will consider when assessing whether a member firm’s level of cooperation during the course of a regulatory investigation can be considered to be “extraordinary” and thus potentially influence a sanctioning determination. The factors include: self-reporting of violations, extraordinary steps to correct deficient procedures and systems, extraordinary remediation to customers and providing substantial assistance to FINRA investigations. The FINRA Notice provides additional detail on each of the factors listed above.