FINRA lacks subpoena power. In lieu, Rule 8210 is the backbone of its self-regulatory framework. Failure to comply or providing incomplete or untruthful responses can lead to severe sanctions, including expulsion for firms and bars for individuals.

At its core, Rule 8210 authorizes FINRA to require information orally, in writing, or electronically, and to compel testimony at a location designated by FINRA—often a U.S. office. It also authorizes the inspection and copying of books, records, and accounts in the possession, custody, or control of a member or any associated person. The scope is not confined to records that must be retained under SEC or FINRA recordkeeping rules. It extends to other books and records a broker-dealer makes or keeps relating to its operations or a person’s association with the firm.

Therefore, FINRA Notice 25-11 (“Notice”) serves as a pointed reminder: members and associated persons, wherever located, must comply fully and promptly with FINRA Rule 8210. The rule empowers FINRA to require information, testimony, and the inspection of books and records in support of examinations, investigations, and disciplinary proceedings.

The reminder is especially salient for firms with global footprints. Some jurisdictions have laws that may conflict with the Requirements of Rule 8210. However, the Notice makes clear that Rule 8210 contains no exception based on foreign law, and members remain responsible for producing information and appearing for testimony as directed by FINRA staff.

For compliance and legal functions, the practical implications are concrete. Firms must be able to locate, collect, review, and produce responsive information across jurisdictions and entities, including affiliates and vendors, on timelines set by FINRA staff. They must also ensure associated persons, members, or other persons subject to FINRA’s jurisdiction are available for on-the-record (OTR) testimony when requested. Where data resides outside the United States, production may require careful navigation of local laws. Nevertheless, the Notice underscores that such constraints do not excuse noncompliance under FINRA rules.

Supervision is the linchpin. FINRA Rule 3110 requires a supervisory system reasonably designed to achieve compliance with all applicable laws and rules, including Rule 8210. That means global firms may need to assess whether their supervisory procedures, contractual frameworks, and operational capabilities can enable timely responses to 8210 requests. This assessment may include whether the firm can request and retrieve records from third-party providers; whether data mapping covers all relevant systems, locations, and affiliates; whether cross-border data transfer mechanisms are in place and tested; and whether personnel understand obligations to provide information and appear for testimony at locations designated by FINRA.

Membership applicants face a similar dynamic. As part of the Membership Application Program, FINRA may require assurances that the applicant and its associated persons can comply with Rule 8210 in practice.

FINRA’s message is unequivocal: geography does not dilute Rule 8210. Members and associated persons must be ready to produce information, books and records, and testimony upon request, and to do so truthfully, completely, and promptly. In an increasingly global and outsourced operating environment, that readiness is not a given—it is a supervisory, legal, and operational imperative. If you have questions about compliance issues, you should contact a qualified legal advisor.