Total FINRA fines are down for the first half of this year to $37.5 million, but not far off last year's historic high, according to the newest installment of a recurring study by the law firm Sutherland Asbill & Brennan.

Total fines imposed by the industry regulatory organization against registered representatives dropped about 12% for the first half of this year compared with the same time last year, from $42.4 million for the first six months of last year, the study found.

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