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pc nid 92672 May 19, 2026 ggallwey@vixio.com US Track 3 Media - Financial Industry Regulatory Authority (FINRA) financial services
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Financial Industry Regulatory Authority Announces Review of Higher-Risk Structured Products

On May 19, 2026, the Financial Industry Regulatory Authority (FINRA) announced it will review member firm practices regarding higher-risk structured products, specifically non-principal protected "worst-of" structured notes. The review will examine how firms supervise concentrations in these products and ensure compliance with Regulation Best Interest and FINRA rules when registered representatives recommend them to investors. Structured products combine traditional securities, such as bonds, with derivative components to meet specific investment objectives including growth, income, or risk management. Unlike mutual funds or exchange-traded funds (ETFs), structured notes do not hold an actual underlying portfolio; instead, the note issuer promises to pay a return based on a formula incorporating the performance of one or more reference assets. While structured products may offer higher return potential than their reference assets, they present unique risks. "Worst-of" notes—which provide payoffs depending on the worst performing reference asset in a pre-specified group—present particularly complex features warranting heightened supervisory scrutiny. FINRA has identified multiple instances where firm representatives concentrated customer assets in structured products lacking principal protection and featuring "worst-of" characteristics. Highly concentrated investments in complex products pose elevated risk, with some investors losing significant portfolio portions through such concentrated positions. Structured notes can expose investors to losses uncorrelated with overall market conditions. While FINRA's review will affect only a subset of member firms, the organisation encourages all firms recommending these products to review their training, guidance, controls, and supervisory structures. Firms should evaluate their practices against the questions outlined in FINRA's guidance letter. Additional compliance guidance and examples of effective practices are available on FINRA's website and in its Annual Regulatory Oversight Report.

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US Financial Industry Regulatory Authority Announces Review of Higher-Risk Structured Products

On May 19, 2026, the US Financial Industry Regulatory Authority (FINRA) announced that it will conduct a targeted review of member firm practices relating to higher-risk structured products, particularly non-principal protected “worst-of” structured notes. The review will examine how firms supervise concentrations in these products and assess compliance with Regulation Best Interest (Reg BI) and FINRA supervisory obligations when registered representatives recommend such products to retail investors. FINRA stated that it has identified multiple instances where firms concentrated customer assets in complex structured products with heightened risk characteristics, including products lacking principal protection and notes linked to the worst-performing reference asset in a basket. According to FINRA, these products may expose investors to losses that are not correlated with broader market conditions and can generate amplified risks when held in concentrated positions. FINRA noted that some investors have suffered significant portfolio losses linked to these exposures. The regulator indicated that the review will focus on: supervisory controls over concentration risk; training and guidance provided to registered representatives; internal compliance and escalation procedures; product governance frameworks; and suitability and Reg BI compliance processes for structured product recommendations. Although the review is expected to affect only a subset of member firms, FINRA encouraged all firms recommending structured products to reassess their supervisory and compliance practices relating to complex retail investment products.