This enforcement action draws a distinction between "churning" and "excessive trading," although it does not define where the line between the very similar violations lies. "Excessive trading" is described as a violation of FINRA Rule 2111 ("Suitability"), while churning constitutes both a violation of Rule 2111 and Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder - meaning churning rises to the level of a violation of law, not merely a violation of a FINRA…

In anticipatory counterpoint to the arguments of the State enforcement authorities, the Administration argued that the regulatory burdens imposed by the CFPB since inception have "cost consumers between $237-$369 billion, including fiscal costs, increased borrowing expenses, and reduced originations." (See,  (February 2026)).  

The SEC in a good number of stocks n 2025. Many of these were organized in an island jurisdiction with main offices in Asia. Even when it is evident that the issuer's securities are of little value, regulatory action to remove them from the market appears excessively deliberate.  

The SEC has provided substantial notice that it will be pursuing enforcement actions against firms claiming market maker status without proper justification. The concept is quite explicit: firms claiming a market maker exemption from the locate requirement must be able to demonstrate that the relevant transactions are in the course of making a market.