Expungement Tips by Amandeep Kalhar

July 2026

Key Rule Changes that Can Affect Your Expungement

FINRA’s 2023 amendments to its expungement rules have significantly changed the process for registered representatives seeking to remove eligible customer dispute information from their CRD records. The amendments are designed to place greater emphasis on timeliness and procedural safeguards.

Key changes include:

• Strict filing deadlines. The new expungement amendments provide that straight-in expungement requests generally must be filed within two years after the conclusion of the related customer arbitration or civil litigation, or three years after a customer complaint is first reported to the CRD if it does not result in litigation or arbitration.
• In-Person or video attendance required. Registered representatives requesting expungement are no longer permitted to attend the hearing telephonically and must appear at the hearing, either in person or by video conference.
• Greater customer participation. Customers are encouraged to attend expungement proceedings.
• Specialized arbitration panels. Most expungement requests are now decided by a three-person panel selected from FINRA’s Special Arbitrator Roster, replacing the previous practice of using a single arbitrator.These amendments make early case evaluation more important than ever. Financial professionals considering expungement should act promptly to preserve their rights and ensure compliance with FINRA’s updated procedural requirements.

  For more information or assistance, please contact us at 619.298.2880 or email [email protected].

June 2026

Best Practices for Form U5

A Form U-5 disclosure can have lasting consequences long after a registered representative leaves a firm. Customer complaints, employment terminations, internal investigations, and other reportable events can become part of an individual’s Central Registration Depository (CRD) record. In addition, recent FINRA rule amendments have made expungement proceedings more rigorous by imposing strict filing deadlines, requiring hearings before specially trained arbitrators, increasing customer participation rights, and permitting greater regulatory oversight. As a result, waiting to address problematic disclosures can significantly limit available options.

To help protect your professional reputation and future career opportunities, consider the following best practices:

•  Regularly review disclosure history to assess whether any reported information may be inaccurate, misleading, or otherwise eligible for expungement.
•  Review Forms U-4 and U-5 for accuracy whenever employment changes occur.
•  Monitor CRD records regularly to identify potentially harmful or inaccurate disclosures.
•  Preserve emails, records, client communications, and other documentation that may support a future expungement request.
•  Be aware of FINRA’s filing deadlines, including the new amended two-year and three-year limitations applicable to many straight-in expungement requests.
•  Consult experienced legal counsel as soon as a negative or unwarranted disclosures appears to evaluate available remedies and develop a strategy.

By doing this, financial professionals can better safeguard their reputations and preserve future employment and business opportunities.

For more information or assistance, please contact us at 619.298.2880 or email [email protected].