McBride v. Financial Industry Regulatory Authority, Inc.
CourtDistrict Court, District of Columbia
Date FiledAugust 10, 2026
DocketCivil Action No. 2025-0960
JudgeJudge Ana C. Reyes
StatusPublished
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Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WILLIAM JOHN MCBRIDE, JR.,
Plaintiff,
Case No. 25-cv-960 (ACR)
v.
FINANCIAL INDUSTRY REGULATORY
AUTHORITY, INC.,
Defendant.
MEMORANDUM OPINION AND ORDER
Like many professionals, Plaintiff William John McBride, Jr., received the occasional
negative review. Because he is a broker, the Securities Exchange Act of 1934 (Exchange Act)
requires the disclosure of the five customer complaints he has accumulated since 2008 in an
online system accessible to the public. Plaintiff sued the Financial Industry Regulatory Authority
(FINRA), the entity responsible for maintaining the system, seeking to expunge those complaints
from his records.
However, for the reasons described below, no federal law authorizes such a suit.
Accordingly, the Court GRANTS FINRA’s Motion to Dismiss, Dkt. 19.
I. BACKGROUND
A. FINRA
The federal government and private entities, known as self-regulatory organizations
(SROs), work together to regulate the securities industry. SROs “date back centuries to when
groups of securities traders adopted self-governing rules by which they would conduct business
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and ensure public trust in their operations.” Alpine Sec. Corp. v. FINRA, 121 F.4th 1314, 1318
(D.C. Cir. 2024).
FINRA, a private, not-for-profit Delaware corporation, is an SRO that “regulates and
oversees large parts of the securities industry” as the only (currently) registered national
securities association under the Exchange Act, as amended, 15 U.S.C. § 78o-3. Alpine Sec.
Corp, 121 F.4th at 1318, 1321.1 The Act sets forth a “regulatory model” for the securities
industry that “depends on the [Securities and Exchange Commission’s (SEC’s)] delegation of
certain governmental functions to” FINRA. In re Series 7 Broker Qualification Exam Scoring
Litig., 548 F.3d 110, 114 (D.C. Cir. 2008). At the same time, the SEC performs oversight. See
15 U.S.C. § 78s. So, for example, it must approve all FINRA rules. See id. § 78s(b).
FINRA, in turn, regulates most firms and individuals that trade securities, because
“federal law effectively requires” that they “join FINRA as a condition of engaging in that
business.” Alpine Sec. Corp., 121 F.4th at 1318.2 “When its member brokers or associated
persons violate FINRA’s rules, FINRA disciplines them pursuant to the Exchange Act’s
requirements.” Turbeville v. FINRA, 874 F.3d 1268, 1271 (11th Cir. 2017).
As relevant here, FINRA must “maintain a system for collecting and retaining
registration information” of member firms and associated persons, including brokers. 15 U.S.C.
§ 78o-3(i)(1)(A). Such registration information includes “disciplinary actions, regulatory,
judicial, and arbitration proceedings, and other information required by law, or exchange or
1
FINRA was formed after the SEC approved a merger between the National Association of
Securities Dealers, the first registered securities association in 1939, and the New York Stock
Exchange’s enforcement arm. See Alpine Sec. Corp., 121 F.4th at 1321.
2
Private individuals, rather than government employees, operate FINRA. See Alpine Sec. Corp.,
121 F.4th at 1321. FINRA accepts no government funding, but rather funds itself through “fees,
fines, penalties, and sanctions levied against its members.” Id.
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association rule,” as well as “the source and status of such information.” Id. § 78o-3(i)(5). In
addition, FINRA must “adopt rules establishing an administrative process for disputing the
accuracy of information provided.” Id. § 78o-3(i)(3).
FINRA aggregates this information in an electronic database known as the Central
Registration Depository (CRD). Consistent with its statutory duties, FINRA also makes certain
information from the CRD available to the public through an online investor protection tool,
BrokerCheck. See SEC Release No. 34-62476, 75 Fed. Reg. 41254, 41254 (Jul. 15, 2010); see
also § 15 U.S.C. 78o-3(i) (mandating that FINRA “establish . . . a readily accessible electronic or
other process[] to receive and promptly respond to inquiries regarding registration information
on [FINRA’s] members and their associated persons”).3
“[I]nformation disclosed on BrokerCheck includes summary descriptions of complaints
lodged by aggrieved customers against individual brokers alleged to have committed sales
practice violations, known as ‘customer dispute’ information.” Tuberosa v. FINRA., No. CV 25-
963 (BAH), 2026 WL 25831, at *2 (D.D.C. Jan. 5, 2026). Altogether, such information helps
investors make informed decisions about brokers they may hire. See 87 Fed. Reg. 50170, 50172
(Aug. 15, 2022).
Brokers are not helpless, however, when faced with inaccurate disclosures. FINRA Rules
2080, 12805, and 13805 set forth standards for the expungement of customer dispute
information. But because “[b]oth regulators and the investing public are disadvantaged when
factual information is removed from the CRD,” a regulated party must clear a “high” bar. 79
Fed. Reg. 43809, 43812–13 (July 28, 2014). In general, expungement “requir[es] a finding that
3
The BrokerCheck database is available at BrokerCheck by FINRA,
https://brokercheck.finra.org.
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the claim or allegation is factually impossible, clearly erroneous or false, or that the registered
person was not involved in the alleged wrongdoing.” Id. at 43812. FINRA Rule 8312(b)(2)(D)
also provides a non-expungement remedy: regulated parties may submit “Broker Comments” in
BrokerCheck providing context concerning a customer complaint.
B. Procedural Background
Plaintiff is a broker who first registered with FINRA in 1998. See Dkt. 19-3 (McBride
BrokerCheck Report).4 He has since worked for seven member firms. Id. at 8. In this action, he
seeks to expunge from the CRD five customer dispute disclosures stemming from events
occurring between 2005 and 2018. See Dkt. 1 at 9–24; McBride BrokerCheck Report at 10–16.
As required, the broker-dealer firms for which McBride worked reported the complaints
to FINRA. Dkt. 1 at 9–24.5 Because BrokerCheck duplicates certain information within the
CRD, summaries of the complaints appear in both places. Id. at 10–16; see FINRA Rule 8312
(governing FINRA’s release of certain disclosures through BrokerCheck). For one of the five
complaints, McBride submitted a Broker Comment in BrokerCheck. See McBride BrokerCheck
Report at 12; FINRA Rule 8312(b)(2)(D).
McBride first sued FINRA for expungement in the District of Columbia Superior Court.
See McBride v. FINRA, D.C. Super. Ct. No. 2024-CAB-004697. Before an adjudication on the
4
The Court may consider the BrokerCheck Report because the Complaint incorporates it by
reference. See Hurd v. District of Columbia, 864 F.3d 671, 686 (D.C. Cir. 2017); Dkt. 1 at 9–24.
In any event, none of the information in that document contradicts information in the Complaint
or is dispositive for purposes of adjudicating FINRA’s Motion to Dismiss.
5
For purposes of adjudicating Defendant’s Motion to Dismiss, the Court takes all the allegations
in the Complaint as true. See Air Excursions LLC v. Yellen, 66 F.4th 272, 277 (D.C. Cir. 2023).
4
merits, on September 4, 2024, he voluntarily dismissed the case. See id., Notice to Court to
Dismiss (Sept. 4, 2024).6 Plaintiff then filed this action.
McBride’s Complaint asserts that the disclosures contain “false, clearly erroneous, and
misleading” information about him. Dkt. 1 at 25. He claims that the disclosures “defam[e]” him
and “mislead the public, employers, and regulators.” Id. at 27. He therefore requests the
“equitable relief [of] expungement,” and a declaratory judgment and a permanent injunction with
the same effect, “pursuant to the Court’s inherent equitable power and/or pursuant to FINRA
rules.” Id. at 24–32.
FINRA moves to dismiss. It claims that Plaintiff lacks a cause of action under any
applicable federal law. See Dkt. 19-1 (MTD) at 18–26. On November 20, 2025, the Court held a
motion hearing.
Since that hearing, another federal district court in the District of Columbia has issued an
opinion concerning the same legal issues.7 In Tuberosa v. FINRA, the district court granted
FINRA’s motion to dismiss on the grounds that the plaintiff there lacked a cause of action and
the court could not exercise its purported “equitable powers” to expunge plaintiff’s CRD records.
2026 WL 25831, at *4–7. Though Tuberosa initially appealed to the D.C. Circuit, he voluntarily
withdrew the appeal before an appellate decision on the merits. See Tuberosa v. FINRA, No. 26-
7012, 2026 WL 2055569 (D.C. Cir. July 10, 2026).
The Court concurs with the Tuberosa court’s reasoning in full. Without a viable cause of
action before it, the Court cannot provide McBride expungement relief.
6
McBride did so shortly after the District of Columbia Court of Appeals decided, in a similar
case, that the District of Columbia Superior Court lacks jurisdiction over expungement claims,
which implicate federal questions, under the Exchange Act. See Sum-Slaughter v. FINRA, 320
A.3d 313, 324 (D.C. 2024).
7
The D.C. Circuit has yet to weigh in.
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II. LEGAL STANDARD
On a motion to dismiss, the Court considers whether Plaintiff “state[d] a claim to relief
that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). In so doing,
the Court must take all factual allegations as true. See Ashcroft v. Iqbal, 556 U.S. 662, 669
(2009).
Importantly, “a plaintiff who fails to show that the law authorizes him to bring his lawsuit
fails to state a claim upon which relief can be granted.” Eagle Tr. Fund v. U.S. Postal Serv., 365
F. Supp. 3d 57, 63 (D.D.C. 2019) (Jackson, J.), aff’d, 811 F. App’x 669 (D.C. Cir. 2020); see
Sacks v. Reynolds Sec., Inc., 593 F.2d 1234, 1239 (D.C. Cir. 1978).
III. ANALYSIS
Plaintiff has not established a cause of action under any applicable statute. Indeed, he
concedes the Exchange Act supplies none. But he contends that FINRA Rules and the Court’s
equity power make up for this deficit. They do not—for the reasons the Court articulates below.
A. The Exchange Act Does Not Supply Plaintiff a Cause of Action
Plaintiff has not pointed to a provision of the Exchange Act that authorizes a private right
of action to expunge his CRD records. In fact, at the motion hearing, Plaintiff’s counsel
specifically disclaimed “rel[iance] . . . on the Exchange Act or on any specific provision of it” for
such purposes. Dkt. 24 (MTD Hr’g Tr.) at 10.
Neither does the Court independently discern a statutory cause of action. The Exchange
Act establishes a comprehensive scheme for regulating the securities industry. See In re Series 7
Broker Qualification Exam Scoring Litig., 548 F.3d at 114. So, for example, the Act provides
that FINRA must maintain a system containing members’ “registration information,” including
certain disciplinary or legal actions. 15 U.S.C. § 78o-3(i)(1)(A), (i)(5); see supra pp. 2–3. In
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addition, FINRA is responsible for “adopt[ing] rules establishing an administrative process for
disputing the accuracy of information provided.” Id. § 78o-3(i)(3) (emphasis added).
But the Act lacks the sort of “clear and unambiguous . . . rights-creating terms with an
unmistakable focus on individuals” that would allow McBride to invoke the power of a federal
court, rather than an administrative process, to expunge unfavorable disclosures. Medina v.
Planned Parenthood S. Atl., 606 U.S. 357, 358 (2025) (cleaned up). Here, because the Act does
not reflect congressional “intent to create . . . a private right [and] a private remedy,” the Court
“may not create one, no matter how desirable that might be as a policy matter, or how compatible
with the statute.” Alexander v. Sandoval, 532 U.S. 275, 286–87 (2001).
This interpretation is no outlier. “[F]ederal courts have overwhelmingly declined to find
the availability of a private right of action against FINRA” where the Exchange Act does not
supply one. Tuberosa, 2026 WL 25831, at *5 (cleaned up). So, for example, numerous “courts
have consistently found Congress’s intent under the Exchange Act precludes common law causes
of action.” In re Series 7 Broker Qualification Exam Scoring Litig., 548 F.3d at 113–14 (citing
circuit cases).
The Exchange Act does not permit Plaintiff to sue for expungement relief.
B. FINRA Rule 2080 Does Not Supply Plaintiff a Cause of Action
Contrary to Plaintiff’s assertions, see Dkt. 20 (MTD Opp’n) at 3–6, FINRA itself has no
power to conjure a federal cause of action when no statute supplies one. Plaintiff relies on
FINRA Rule 2080, which provides that “[m]embers or associated persons seeking to expunge
information from the CRD system arising from disputes with customers must obtain an order
from a court of competent jurisdiction directing such expungement or confirming an arbitration
award containing expungement relief.” FINRA Rule 2080(a).
7
But “private rights of action . . . must be created by Congress.” Alexander, 532 U.S. at
286. Consequently, circuit courts have repeatedly held that a FINRA regulation alone cannot
supply the missing link. See Desiderio v. Nat’l Ass’n of Sec. Dealers, Inc., 191 F.3d 198, 208 (2d
Cir. 1999); Spicer v. Chicago Bd. of Options Exch., Inc., 977 F.2d 255, 259 (7th Cir. 1992);
MM&S Fin., Inc. v. Nat’l Ass’n of Sec. Dealers, Inc., 364 F.3d 908, 911 (8th Cir. 2004); Sparta
Surgical Corp. v. Nat’l Ass’n of Sec. Dealers, Inc., 159 F.3d 1209, 1213 (9th Cir. 1998),
abrogated on other grounds by Merrill Lynch, 578 U.S. 374; Turbeville, 874 F.3d at 1277.8 That
the SEC must approve all FINRA rules, see 15 U.S.C. § 78s(b), does not, as Plaintiff suggests,
alter the analysis. See MTD Opp’n at 13. The SEC is not Congress. The “argu[ment] that . . .
regulations contain rights-creating language and so must be privately enforceable” ultimately
“skips an analytical step.” Alexander, 532 U.S. at 291.
It is also at least unclear to the Court whether FINRA itself intended, through Rule 2080,
to allow an expungement action in federal court. Cf. MTD Opp’n at 1, 4. The Rule explains that
expungement requires “an order from a court of competent jurisdiction directing such
expungement or confirming an arbitration award containing expungement relief.” FINRA Rule
2080(a) (emphasis added). But it does not elaborate on what courts might have such
“competen[ce].” So, the Tuberosa court is likely correct that the Rule “simply serves to cabin
when FINRA may expunge customer dispute information from CRD.” 2026 WL 25831, at *6.
That is, the Rule applies to FINRA itself, not to the courts. In any case, for the reasons described
above, it makes no difference what FINRA, rather than Congress, intended.
8
Judge Howell’s opinion collects other similar district-court cases. See Tuberosa, 2026 WL
25831, at *5.
8
Finally, Plaintiff cites to a state-court and a Western District of Texas case to support his
interpretation. See MTD Hr’g Tr. at 4; MTD Opp’n at 2–3. Neither binds this Court.9 And both
are distinguishable and unpersuasive. In Lickiss, the California Court of Appeals invoked the
state court system’s “inherent equitable powers to weigh the equities” with respect to
expungement from the CRD. See Lickiss v. FINRA, 208 Cal. App. 4th 1125, 1135 (2012). And
the Court has already set forth the reasons it disagrees with the federal district judge in Reinking
that Rule 2080 and “the SEC’s approval” of Rule 2080’s predecessor together “shift final
authority on expungement . . . to courts of law.” Reinking v. FINRA, No. A-11-CA-813-SS, 2011
WL 13113323, at *3 (W.D. Tex. Dec. 1, 2011). In any event, the facts in Reinking are
distinguishable. There, the individuals who submitted a complaint about the broker “stated in
affidavits they had no opposition to expunging the CRD record” following settlement of a related
suit they had brought against the broker. Id. at *2.10
Rule 2080, even read as Plaintiff desires, cannot usurp Congress’s powers to create (or
decline to create) a private right to suit. The FINRA Rules, however, do not leave Plaintiff
entirely without recourse. Plaintiff may seek an arbitral award in favor of expungement, see
FINRA Rule 13805, or leave Broker Comments in BrokerCheck to accompany the disclosures,
see FINRA Rule 8312(b)(2)(D).
9
The District of Columbia Court of Appeals opinion dismissing the Sum-Slaughter case, see
supra n.6, does not either. True, as Plaintiff asserts, see MTD Opp’n at 6–7, that court ruled that
federal courts have jurisdiction over Exchange Act claims generally. See 320 A.3d at 324. But it
never stated that federal courts can definitively provide expungement relief for disclosures in the
CRD and BrokerCheck.
10
Plaintiff’s other citations, MTD Opp’n at 3, to “state court decisions about expungement relief
in situations unrelated to FINRA or the Exchange Act,” such as the expungement of criminal
records, are even further afield of our inquiry. Tuberosa, 2026 WL 25831, at *7.
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C. Plaintiff May Not Assert Equitable Remedies Absent a Statutory Cause of Action
Plaintiff tries one last move. He suggests that “principles of equity” “pursuant to the
Judiciary Act” nevertheless entitle him to sue here. See MTD Opp’n at 13. In his view, the
Court should apply an “equitable balancing test” to evaluate the propriety of expungement relief.
Id.
Plaintiff’s requests for equitable relief, declaratory relief, and a permanent injunction are
remedies, however, not causes of action. See Ali v. Rumsfeld, 649 F.3d 762, 778 (D.C. Cir. 2011)
(explaining the Declaratory Judgment Act does not provide a cause of action); Weinberger v.
Romero-Barcelo, 456 U.S. 305, 311 (1982) (explaining that an injunction is a type of equitable
remedy). And the “question whether a litigant has a cause of action is analytically distinct
and”—even more importantly—“prior to the question of what relief, if any, a litigant may be
entitled to receive.” Davis v. Passman, 422 U.S. 228, 239 (1979) (emphasis added) (cleaned up).
Plaintiff’s asserted remedies do not amount to a statement of a claim. See Abdelfattah v.
U.S. Dep’t of Homeland Sec., 787 F.3d 524, 538 (D.C. Cir. 2015).
D. Leave to Amend
Lastly, the Court denies Plaintiff leave to amend. A “bare request” to do so, as here,
“without any indication of the particular grounds on which amendment is sought,” does not pass
muster under Federal Rule of Civil Procedure 15(a). U.S. ex rel. Williams v. Martin-Baker
Aircraft Co., 389 F.3d 1251, 1259 (D.C. Cir. 2004) (cleaned up); see MTD Opp’n at 15.
Moreover, naming a nebulous, other “defendant party,” as Plaintiff proposes, MTD Opp’n at 15,
would not cure the defect the Court has identified—that under these circumstances, no statute
authorizes Plaintiffs to sue any party for expungement relief. Leave to amend would therefore
be futile. See Rollins v. Wackenhut Servs., Inc., 703 F.3d 122, 131 (D.C. Cir. 2012).
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IV. CONCLUSION AND ORDER
For all these reasons, Plaintiff has not established a private right to sue for the
expungement of the disclosures to which he objects in the CRD and BrokerCheck. The Court
GRANTS Defendant’s Motion to Dismiss, Dkt. 19. It DISMISSES this action with prejudice
and DIRECTS the Clerk of Court to close this case.
SO ORDERED.
This is a final appealable Order. See Fed. R. App. P. 4(a).
Date: August 10, 2026 ____________________________
ANA C. REYES
United States District Judge
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