The main objectives in regulating brokerage activities are to ensure the interests of brokers clients while minimizing the regulatory burden. At the moment, in connection with the flow of households assets to the securities market, the Bank of Russia is actively developing direct tools to protect the interests of investors, including the mechanism for qualifying investors. However, its effectiveness is questioned by the expert and professional community. To assess the results of the use of direct and indirect regulatory instruments aimed at protecting retail investors, a comparative analysis of the regulatory policy in this area in countries with the most developed financial markets was carried out. Based on the results of the analysis of regulation in the United States and China, it was established that they used tools of both direct and indirect regulatory impact. Despite the differ-ences in regulation in both cases, the emphasis in regulation is placed on indirect measures of influence. Direct bans on access to financial instruments for certain categories of investors in the countries under consideration are not applied. It was also noted that despite applying certain measures in Russia, similar to the indirect regulation in the United States and China, their implementation is often sufficient, which reduces their effectiveness.