When an Australian financial services firm is dealing with a US-based broker, adviser, or fund manager, one of the most basic due diligence questions is whether that person or firm has a clean regulatory record with US financial regulators.
FINRA and the SEC both publish this information. FINRA maintains BrokerCheck, a public database of registered broker-dealers and investment advisers that includes disclosures covering customer complaints, regulatory actions, terminations, and permanent bars or suspensions. The SEC publishes litigation releases covering civil injunctive actions and administrative proceedings, updated daily.
The data is public. The challenge is getting it into a compliance workflow in a form that is auditable, consistent, and does not require your team to run manual BrokerCheck searches for every counterparty check.
What FINRA BrokerCheck actually contains
BrokerCheck is a disclosure database, not just a registration list. For each registered broker or adviser, it contains their registration status, the firms they have been registered with, and their disclosure history.
Disclosures are the important part. A disclosure can cover a customer complaint that resulted in a settlement, a regulatory action taken by FINRA or a state regulator, a termination by a prior employer for cause, a financial disclosure such as a bankruptcy, or a criminal matter. Not all disclosures are equal in severity. A single settled customer complaint is a different signal than a FINRA bar or a pattern of regulatory actions across multiple firms. But the presence of disclosures is a material fact for due diligence, and the absence of a lookup is an absence of evidence, not evidence of absence.
Permanent bars are the most significant flag. A broker who has been permanently barred by FINRA cannot legally act as a broker-dealer or be associated with a FINRA member firm. Finding a bar in a BrokerCheck record during due diligence, rather than after the relationship has been established, is exactly what the disclosure system is designed to enable.
The cross-border adviser problem
This is particularly relevant for Australian firms. An Australian financial services firm dealing with a US-based adviser or distributor relationship is not automatically plugged into the FINRA disclosure system. ASIC licensing checks cover Australian registrations. They do not surface a FINRA bar or a pattern of SEC enforcement actions against a US counterparty.
The practical result is that cross-border adviser due diligence often does not happen at the data level. A firm might check that its US counterpart is a registered entity and stop there. The disciplinary history question gets answered with "they're a licensed broker-dealer" rather than "we checked BrokerCheck and there are no disclosure events."
That gap is a compliance risk. It is also the kind of gap that comes up in examinations and audits when something goes wrong with a counterparty relationship.
What SEC litigation releases add
FINRA BrokerCheck covers registered individuals and firms in the broker-dealer and investment adviser space. SEC litigation releases cover a broader range of enforcement actions including civil injunctive proceedings and administrative actions that may involve entities or individuals not registered with FINRA.
For counterparty due diligence on US-listed companies or US fund managers outside the pure broker-dealer context, SEC enforcement data provides a second check that BrokerCheck does not cover. The combination gives a more complete picture of a counterparty's regulatory standing with US financial authorities.
Why a manual BrokerCheck search is not a compliance process
FINRA provides a public BrokerCheck search interface. Anyone can run a search. The problem with treating that search as a compliance process is the same problem that applies to all manual lookups. There is no structured record of the search, no consistent schema for the result, no timestamp, and no audit trail.
When your compliance team checks a counterparty adviser on BrokerCheck and finds nothing, that check exists as a memory, maybe a note, possibly a screenshot. It is not a structured entry in a compliance log that can be produced on demand to demonstrate that the check was performed at a specific point in time and returned a specific result.
For regulated entities, the standard is not whether the check happened. It is whether the check is documented in a way that can be verified.
What the Tech Compass US Enforcement and Disciplinary API provides
The API provides on-demand lookup of FINRA BrokerCheck records by CRD number, returning registration status, firm history, and disclosure summary in a structured schema. FINRA data is fetched on demand and cached for 24 hours, with a daily refresh pipeline keeping the cache warm for frequently checked entities.
SEC litigation releases are indexed daily and searchable by entity name, providing structured access to civil and administrative enforcement actions.
Every call generates an audit log entry before the response is returned: the entity checked, the CRD number or identifier used, the timestamp, the result summary, and a request ID. Your compliance documentation has a structured record of every disciplinary check your team performs.
Tech Compass holds written permission from FINRA for commercial redistribution of BrokerCheck data (Case CAS-2946202-V7L1H3). The licensing position is documented in the compliance pack.
Pricing and access
Free tier covers 10,000 calls per month with no credit card required. Professional plan is USD 1,500 per month and includes the full SLA, audit logging, and compliance pack.
Documentation is at api.techcompass.com.au/docs. The compliance pack includes the FINRA permission reference, data lineage documentation, and a pre-filled vendor questionnaire response.
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Free tier covers 10,000 calls per month. No credit card required.
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