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What FINRA’s 6th National Financial Capability Study Means for Compliance & Supervision Teams
Americans are financially stressed, and compliance teams are about to feel it.
Every three years since 2009, the FINRA Investor Education Foundation surveys ~25,500 U.S. adults regarding financial behaviors, attitudes, and knowledge. The sixth wave, data collected June through October 2024, and released July 2025, paints a concerning picture of Americans’ financial resilience amid rising costs, the mainstreaming of mobile finance, and growing curiosity about AI-driven advice. These trends don’t just affect clients; they’re reshaping how firms must supervise advice, marketing, and communication.
Below are five of the points that stand out from the survey:
1. Spending Outpacing Income
Study Highlight: More U.S. adults report spending more than they earn, and satisfaction with overall finances has dropped sharply. Two‑thirds say food‑cost spikes forced them to cut back on other spending.
When clients are stretched thin, complaints and scam reports rise. Regulators will start asking tougher questions about whether advice truly fits a client’s situation and if marketing lives up to its promises, and you can bet they’ll tighten or more strictly enforce the rules around financial advice and advertising.
2. Emergency Savings Gap Widens
Study Highlight: Only 46 % of adults can cover three months of living expenses from savings—down from 53 % in 2021. Seven points in 3 years is nothing to balk at.
Clients may liquidate positions or rush into quick‑liquidity products. All communications around these transactions must be captured and reviewed for sales‑practice and liquidity‑risk compliance. Be sure to archive all client communications securely.
3. Mobile Banking Is Mainstream
Study Highlight:
- 81 % use mobile devices to access checking or savings accounts
- 65 % use phones for peer‑to‑peer transfers
- 53 % make in‑person purchases via mobile wallet
This isn’t a surprise; all industries have been moving more towards mobile interaction, but still worth noting. Regulated conversations increasingly occur over mobile chat and payment platforms (e.g., WhatsApp, Venmo). Archival scope must extend beyond e‑mail to include these channels.
4. Interest in AI‑Powered Advice Rises
Study Highlight: 20 % of U.S. adults would consider getting financial advice from artificial intelligence, 30 % among those aged 18–34
Firms experimenting with AI chatbots or algorithmic recommendations must implement transparent governance frameworks and archive logs of every client‑bot interaction for audit and supervisory review.
5. Buy Now Pay Later (BNPL) Usage Jumps
Study Highlight: 23 % of adults have used BNPL services in the past year.
As stated in the study, “BNPL arrangements allow consumers to split the cost of a purchase into a few (typically four or fewer) equal payments over a short period of time. “
Clients juggling BNPL debt may underreport liabilities during suitability assessments. Supervisory processes should flag communications that reveal undisclosed credit burdens and trigger follow‑up.
Action Items for Compliance & Tech Teams
- Expand Archival Coverage – Include SMS, WhatsApp, Venmo, Teams, Signal, etc, in your capture policy.
- Integrate financial stress indicators (e.g., low emergency savings) into risk-scoring models.
- Build policies for BNPL and installment terms related to client communications.
- Equip advisers and reps to spot signs of financial distress and escalate potential suitability or best‑interest issues. At Comma, we believe compliance needs human oversight, not just automation. AI engines can help flag real-life language, humans can quickly discern whether a flagged communication may be a sign of financial distress.
In today’s financial landscape, where every text message, mobile payment and AI interaction can carry risk, compliance isn’t a checkbox.
It’s about being transparent with your clients, building trust through clear policies, and keeping a human in the loop.
Start by mapping your firm’s blind spots against these FINRA-highlighted trends:
- Are you really capturing WhatsApp, etc. convos?
- Do your risk models flag clients running low on emergency savings?
- Are BNPL obligations fully surfaced in reviews?
By combining smart tech with thoughtful oversight, and by sharing your approach openly with both regulators and clients, you can stay ahead of the next round of rules, and you’ll earn deeper loyalty. That’s compliance done right. Protect your firm and above all, safeguard the trust your clients place in you.
If you’re interested, you can read the entire FINRA report here.
Data Sources:
All charts: FINRA Investor Education Foundation, 6th National Financial Capability Study (2025).
