On October 27, 2001, the SEC ordered FINRA to obtain, within 30 days, the services of an independent consultant that will:

  • conduct a one-time comprehensive review of FINRA's policies and procedures and training relating to document integrity
  • determine whether the policies and procedures and training are reasonably designed and implemented to ensure the integrity of documents provided to the SEC
  • recommend the necessary enhancements of FINRA's policies and procedures and training as result of the independent consultant's review and determination  

This order is the result of three instances over an eight-year period in which a FINRA, or its predecessor, National Association of Securities Dealers, employee provided altered or misleading documents to the SEC. Most recently, on August 7, 2008, the Director of FINRA's Kansas City District Office had three documents of staff meeting minutes altered just hours before the documents were produced to the SEC's Chicago Regional Office, causing the documents to be inaccurate and incomplete.

FINRA, without admitting or denying these findings, consented to the order, which also requires it to cease and desist from committing or causing future violations of Section 17(a) of the Securities Exchange Act of 1934 and Exchange Act Rule 17a-1.