The Financial Industry Regulatory Authority is on pace for a significant yearly increase in fines and disciplinary actions against broker-dealers and their associates, according to a new analysis by the law firm Sutherland & Asbill and Brennan.

In the first half of 2012, FINRA has levied fines of $39.4 million, Sutherland found, a figure that includes a growing number of so-called "super fines," or penalties that exceed $1 million.

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