FINRA's remote inspection pilot ends June 2027. What comes next?

When does the FINRA Rule 3110.18 remote inspection pilot end?

The pilot ends June 30, 2027. Rule 3110.18 took effect July 1, 2024 as a voluntary, three-year program, and Regulatory Notice 24-02 splits it into four pilot years, the last of which runs from January 1, 2027 to June 30, 2027.

For a CCO who built the 2027 inspection calendar around remote reviews, that end date matters more than it looks. The pilot is the only thing that lets a broker-dealer satisfy its Rule 3110(c) inspection obligation without sending someone to the office. FINRA's own pilot page states that firms outside the program must inspect each OSJ, branch office, non-supervisory branch office and non-branch location on-site, under the joint guidance in Regulatory Notice 11-54. If nothing replaces the pilot by mid-2027, firms that relied on remote reviews will need a different plan for the second half of the year.

Is FINRA making remote inspections permanent?

FINRA intends to, but no permanent rule is in effect yet. At its June 3 to 4, 2026 meeting, the FINRA Board of Governors approved a proposal that "would make permanent the Remote Inspections Pilot Program before it expires." In an October 12, 2026 update on its rule modernization work, FINRA said it plans to propose making the pilot permanent "before it expires next year" and added that "brokers with specified disciplinary issues will not be in scope for this rule."

A FINRA rule change like this one generally does not take effect until the SEC approves it, and the SEC process includes publication and a comment period. As of late October 2026, there is no approved permanent rule and no effective date. Treat the June 30, 2027 sunset as the operative date until FINRA or the SEC says otherwise.

What else did the FINRA Board approve in June 2026?

The Board also approved a separate proposal on supervision locations. According to the Board report, it would extend the presumptive inspection cycle for non-branch locations and modify the supervisory ineligibility requirement for Residential Supervisory Locations. Residential Supervisory Locations are currently governed by Rule 3110.19.

Today, Rule 3110 presumes non-branch locations, including residential supervisory locations, are inspected at least every three years, while OSJs and branch offices that supervise non-branch locations must be inspected at least annually on a calendar-year basis. Those cycles stay in place until a rule change is approved. Our earlier piece on residential supervisory location requirements covers the RSL conditions in detail.

What could change between the pilot and a permanent rule?

The direction is clear, but the details are not final. The one change FINRA has described publicly is scope: associated persons with specified disciplinary issues would be outside a permanent rule. The current pilot already excludes a long list of firms and locations, so firms should expect the permanent version to keep a similar structure of conditions.

Under the pilot text in Attachment A to Regulatory Notice 24-02, a firm is ineligible if it is a Restricted Firm under Rule 4111, a Taping Firm under Rule 3170, suspended by FINRA, a member for less than 12 months, or found in the past three years to have violated Rule 3110(c). A location is ineligible if, among other things, someone there is on a mandatory heightened supervisory plan, is statutorily disqualified, engages in proprietary trading, or if the location handles customer funds or securities.

The pilot also conditions eligibility on technology. Electronic communications must run through the firm's systems, correspondence must be subject to supervision under Rule 3110, and no required books and records may be kept at the location. The firm must also determine that its surveillance and technology tools, including "secure network connections and effective cybersecurity protocols," are appropriate for the risks each location presents.

What happens to your 2027 inspections if the pilot lapses?

Any location you planned to inspect remotely after June 30, 2027 would need an on-site inspection instead, unless a permanent rule is in effect by then. That is a scheduling problem as much as a compliance one.

OSJs and supervising branch offices must be inspected every calendar year. A firm that relied on remote inspections for those offices and scheduled them for the third or fourth quarter of 2027 could find itself needing travel, staff time and on-site access it did not budget for. Moving annual inspections into the first half of 2027, while the pilot is still in force, is one way firms can reduce that exposure.

What does Pilot Year 4 still require?

Participation in the final pilot year carries the same documentation and reporting duties as earlier years, compressed into six months. The pilot page and Regulatory Notice 24-02 set these dates:

• December 27, 2026: deadline to opt in to, or opt out of, Pilot Year 4. Current participants who do nothing are deemed to continue.
• April 15, 2027: supplemental written supervisory procedures and Pilot Year 4 first-quarter data due.
• June 30, 2027: the pilot ends.
• July 15, 2027: Pilot Year 4 second-quarter data due.

The quarterly data under Rule 3110.18(h) counts inspections completed, how many were remote or on-site, how many on-site inspections were triggered by a finding, and how many remote and on-site inspections produced findings, with a list of significant findings. Participants must also keep a centralized record of every location inspected remotely and any location placed under added supervisory procedures.

What should firms do this quarter?

Use the next 60 days to make the Pilot Year 4 decision on purpose and to build a fallback. Practical steps:

• Confirm by December 27, 2026 whether the firm will stay in, join or leave the pilot for 2027, and document who made the decision and why.
• Re-run eligibility checks for every location you plan to inspect remotely in 2027. Changes in heightened supervision, disciplinary events or proprietary trading can remove a location mid-year.
• Map 2027 inspections by quarter. Flag every annual inspection currently scheduled for July through December that depends on a remote review.
• Confirm your technology still meets the pilot conditions at each location: firm email and messaging only, no local records, endpoint and network controls you can evidence, and surveillance that covers the activities and products at that office.
• Assemble the inspection evidence now (device inventories, access reviews, archive confirmations, patch and encryption status) so it can support either a remote review or an on-site visit.
• Watch FINRA's rule filings and the SEC's SRO rulemaking pages for the permanent proposal. Once it is published, compare its conditions to your current procedures and note any gaps before the comment period closes.

Our earlier article on what evidence your technology must produce for a remote inspection goes deeper on the records examiners and inspectors expect to see.

How does s90 help?

s90 supports broker-dealers and dual-registered firms with managed IT built around supervision and exam evidence. For firms using remote inspections, that means firm-controlled communications, centralized records, device and access reporting by location, and evidence packages that support either a remote or an on-site review. Our agreements include 72-hour breach notification and 24-hour evidence production. If you want a second look at your 2027 inspection plan before the December 27 deadline, we are happy to talk it through.