Effective March 22, 2011, FINRA has revised its Sanction Guidelines to reflect recent developments in FINRA disciplinary cases. The specific revisions:
-clarify the standards required for an order of restitution (repayment)
-recognize that adjudicators may order that ill-gotten gains be paid to the injured party (as opposed to being taken by FINRA as a fine)
-acknowledge that whether a factor is aggravating or mitigating depends on the circumstances of the case
-direct adjudicators to consider sanctions already imposed by other regulators for the same misconduct to see if those sanctions were “sufficiently remedial”
http://www.finra.org/Industry/Regulation/Notices/2011/P123374