If your firm is evaluating whether to opt into Pilot Year 3 of FINRA’s Remote Inspections Pilot Program, there’s a lot to weigh – and a compelling case for leveraging a specialized audit management solution. Established under FINRA Rule 3110.18, which took effect July 1, 2024, the program is a voluntary, multi-year initiative (running through June 30, 2027) that permits eligible firms to conduct required inspections remotely, under defined conditions, instead of through traditional on-site visits. Firms that do not enroll must continue to meet Rule 3110(c) obligations with in-person inspections. Participation in the pilot requires documented risk assessments, updated written supervisory procedures that reflect the use of remote technology, and quarterly reporting of inspection data to FINRA – requirements that underscore the importance of having the right processes and tools in place to ensure compliance and oversight.
Program years and enrollment windows
- Pilot Year 1: July 1, 2024 – December 31, 2024
- Pilot Year 2: January 1, 2025 – December 31, 2025
- Pilot Year 3: January 1, 2026 – December 31, 2026
- Pilot Year 4: January 1, 2027 – June 30, 2027
Eligible firms have until December 27, 2025 to opt in to Year 3.
Enrolling implies a commitment to comply with the program’s requirements for the full pilot year; a participant cannot simply stop reporting mid-year.
What FINRA is observing so far
FINRA has publicly noted considerable interest in the pilot:
- When the pilot launched in mid-2024, a total of 741 member firms opted in.
- Those 741 firms represent about 22% of FINRA member firms.
- Among large firms (500+ registered reps), participation was significantly higher: 60% opted in. Mid-size firms saw a 47% uptake, and small firms about 18%.
- In terms of footprint, participant firms cover 67% of all FINRA registered reps and 53% of registered branches.
The scale of participation, especially among larger firms, suggests that many see remote inspections as a promising modernization of supervisory practices.
That said, the pilot is still in its early stages, and FINRA has been clear that it will assess, over time, whether remote inspections maintain the same level of oversight integrity as traditional inspections.
Finally, a related development: FINRA has also adopted Rule 3110.19, which allows certain Residential Supervisory Locations (RSLs) – private residences used for supervisory functions – to be treated under a different inspection regime (i.e. subject to inspections at least every three years). And if a firm opts into the pilot program, those RSLs may be inspected remotely under the pilot’s framework.
Why Consider Joining in Year 3? (What to Weigh)
If your firm has held off thus far, Year 3 could offer a midway point where many uncertainties may have been addressed, pilot “kinks” smoothed out, and peer experience available. Here are some pros and risks to consider:
Pros / potential advantages
- Remote inspections can reduce travel, time, and logistical costs associated with on-site audits.
- Flexible scheduling and reduced disruption of operations.
- Ability to modernize oversight practices in line with hybrid and remote work models.
- Firms that participate will be better positioned to influence and adapt to how FINRA may shape inspection rules going forward.
- Balancing remote and onsite inspections, allows firms to apply in-person resources where risks are highest and use remote reviews for lower-risk locations, creating a more efficient compliance program.
Risks / challenges / things to ensure
- Ensuring your technology, security, and documentation meets FINRA’s expectations.
- Not all offices or locations will necessarily be eligible for remote inspection – some may still require on-site follow-up due to red flags or risk metrics.
- Committing to quarterly reporting obligations, including distinguishing remote vs. on-site results, significant findings, escalations, etc.
- Ensuring your written supervisory procedures (WSPs) are updated and robust to address remote inspection nuances (technology usage, escalation procedures, etc.).
- A firm must continue to treat high-risk or flagged locations carefully; a remote inspection does not fully eliminate the need for on-site oversight in certain cases.
- The pilot is experimental: outcomes and regulatory expectations may evolve.
Given those uncertainties, effective planning, process discipline, and flexible systems are key. That’s where a partner like RegEd can play a strategic role.
How RegEd Helps Firms Navigate Remote Inspections
RegEd’s offerings are already aligned to address many of the needs and challenges firms face in preparing for and executing remote inspections. Here’s how we help:
Audit Management capabilities built for the pilot
In our blog post “RegEd Continues Expansion of Audit Management Capabilities in Support of FINRA’s Remote Inspections Pilot Program,” we detail multiple enhancements designed to support firms whether or not they choose to participate.
Some of the standout features:
- Remote vs. On-site designation and tracking
You can tag inspection engagements as remote or on-site, helping manage the blend of approaches your firm will likely adopt.
- Significant findings management
You can define what constitutes a “Significant Finding” internally, then track, escalate, remediate, and report on those findings systematically.
- Flexible, enhanced reporting
Built-in reporting capabilities help satisfy FINRA’s quarterly data requirements under Rule 3110.18. For example: number of inspections (remote vs. on-site), number of findings and significant findings, categorization of those findings, and details on escalations/remediation.
- Risk-driven auditing tools
Firms can use prior audit history, risk assessments, and past findings (such as WSP gaps or recordkeeping violations) to guide scheduling, helping determine which locations are appropriate for remote exams and which require onsite review.
- Best practices module
RegEd has developed an inspections best practices module (in collaboration with industry inspection programs) to help firms leverage lessons learned and standardize effective audit practices.
- Continuous innovation and roadmap planning
RegEd has committed to ongoing enhancements (e.g. increased automation, AI-assisted workflows) to align with evolving FINRA practice and remote supervision needs.
Additional detail is available in our post “Is your regulatory branch inspection program prepared to support the new FINRA Remote Inspections Pilot Program and Requirements for Residential Supervisory Locations?” which explains how RegEd’s solution supports firms in planning, conducting, and reporting inspections.
Guided implementation and consultation
Adopting remote inspections is more than toggling a system switch—it requires thoughtful process design, compliance reviews, change management, and coordination across operations, IT, and compliance. RegEd can help you:
- Assess readiness
Evaluate whether your firm meets the technological, security, and procedural prerequisites for remote inspections, and identify gaps or upgrades needed.
- Migrate and configure audit solution
Configure your RegEd Audit Management instance to support remote/on-site tagging, workflows, tracking, escalations, remediation, and reporting.
- Pilot remote audits internally
Before going “live,” run tests or hybrid audit pilots internally (or with a subset of locations) to validate processes, refine workflows, and train audit staff.
- Train and support your teams
Provide training for audit staff, operations, compliance, and management on the new workflows, expectations, and reporting demands.
- Ongoing feedback and iteration
As your firm participates in the pilot, we can help incorporate feedback from audits, internal lessons, or FINRA observations back into your processes so that you evolve your approach year to year.
With RegEd’s experience working with firms already in the pilot, we can share practical insights and lessons learned to help you avoid common pitfalls.
Key Steps to Take Now (if You’re Considering Year 3 Participation)
If your firm is leaning toward opting into Pilot Year 3 (2026), here’s a recommended roadmap:
| Timeframe | Key Action Items |
| Now – Q4 2025 | Evaluate your current audit program, technology, and processes. Perform a “remote-audit readiness check.” |
| Q4 2025 | Begin drafting or updating your WSPs to incorporate remote inspection procedures under Rule 3110.18. Conduct a Risk Assessment to identify which branches you will conduct remotely vs. onsite. |
| Late 2025 | Configure or pilot your audit management system (e.g. RegEd) to tag and manage remote vs on-site workflows, escalations, remedial tracking, and reporting. |
| By Dec. 27, 2025 | Submit your opt-in notice via FINRA Gateway for Pilot Year 3. |
| Early 2026 | Launch remote (or hybrid) inspections per your risk-based plan; collect and store all documentation properly. |
| Quarterly (2026) | Submit required data to FINRA (number of inspections, findings, remote vs on-site, significant findings, escalations) per Rule 3110.18(h). |
| End of 2026 / Pilot wrap-up | Assess findings, refine processes, prepare for continued participation (Year 4) or transition plans should FINRA adopt a permanent model or should you wish to discontinue participation in the Pilot Program. |
Note: Submissions for the first quarter of Year 3 are typically due April 15 of that year.
Why RegEd is the Leading Provider of Remote Inspections Solutions
- Purpose-built features that support pilot participation: Unlike generic tools, RegEd’s audit solution includes enhancements designed to meet the pilot program’s specific requirements, such as remote vs. onsite tracking, significant findings categorization, and quarterly reporting.
- Experience from existing participants: RegEd already supports firms participating in the pilot and has accumulated domain knowledge, process templates, and lessons learned – insight you can benefit from rather than reinventing the wheel.
- Scalable and flexible: Whether your firm chooses mostly remote audits, a hybrid mix, or continues with on-site audits, RegEd is designed to adapt and support evolving regulatory expectations.
- Ongoing innovation: We remain committed to enhancing automation, reporting flexibility, risk analytics, and integrations to stay ahead of FINRA’s evolving oversight models.
- Supporting change management: We don’t just provide software—we supply consulting, training, and best-practice frameworks to help your compliance and operations teams collaborate effectively.
The Remote Inspections Pilot Program offers an opportunity for broker-dealer firms to modernize their inspection approach – especially in an era of hybrid and remote work. For firms entering Year 3, the case is stronger than ever: much of the uncertainty has been surfaced by early participants, and support tools like RegEd’s Audit Management are more mature and tuned for compliance.
That said, success depends heavily on preparation, disciplined processes, and the right technology underpinnings. With the opt-in deadline of December 27, 2025 looming for Year 3, now is the time to make decisions, shore up planning, and engage a trusted partner.
If your firm is considering enrollment and would like help assessing readiness and deploying a remote-enabled audit management solution, RegEd would be pleased to assist. Let us guide you through the technical, procedural, and compliance complexities so you can participate confidently in this next wave of supervisory innovation. Schedule a consultation with one of our solution experts today to learn more.
About RegEd
RegEd is the market-leading provider of RegTech enterprise solutions with relationships with more than 200 enterprise clients, including 80% of the top 25 financial services firms.
Established in 2000 by former regulators, the company is recognized for continuous regulatory technology innovation with solutions hallmarked by workflow-directed processes, data integration, regulatory intelligence, automated validations, business process automation and compliance dashboards. The aggregate drives the highest levels of operational efficiency and enables our clients to cost-effectively comply with regulations and continuously mitigate risk.
Trusted by the nation’s top financial services firms, RegEd’s proven, holistic approach to RegTech meets firms where they are on the compliance and risk management continuum, scaling as their needs evolve and amplifying the value proposition delivered to clients. For more information, please visit www.reged.com.