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Bradley Berman

Bradley Berman

Morrison & Foerster LLP


Latest Publications

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Structured Thoughts -- Volume 4, Issue 8 -- May 15, 2013

In This Issue: Due Diligence Procedures for Structured Note Distributors; Key Issues for Yankee CDs; The SEC and FINRA: Protect Your Elders; The FSOC’s 2013 Annual Report: Increasing Exchange-Traded Product Activity;...more

5/16/2013 - Broker-Dealer Due Diligence Elder Issues FINRA FSOC SEC Structured Financial Products

Structured Thoughts -- Volume 4, Issue 6 -- April 26, 2013

In This Issue: FINRA Issues Guidance on Backtested Performance Data; FINRA’s Ketchum Discusses Structured Products; and Update Regarding TRACE and Rule 144A Securities. Excerpt from FINRA Issues Guidance on...more

4/30/2013 - Exchange-Traded Products FINRA Structured Financial Products

Structured Thoughts -- Volume 4, Issue 4 -- February 28, 2013

In This Issue: Additional SEC Guidance on Estimated Value Disclosures; 2013 OCIE Examination Priorities Have Implications for Structured Products Issuers and Dealers; EITF and the Federal Funds Rate; and FDIC Proposes to...more

3/1/2013 - Dually Payable Deposits EITF Estimated Value Disclosures OCIE Prioritized Examination SEC Structured Financial Products

Structured Thoughts -- Volume 4, Issue 3 -- February 6, 2013

In This Issue: Reverse Inquiry Transactions in the Spotlight; How Will the Fed’s Proposed Foreign Bank Rules Affect Foreign Bank Debt Financing Activities in the U.S.?; IOSCO Commences Consultation on Benchmarks; and...more

2/7/2013 - Benchmarks Debt Foreign Banks IOSCO Regulation T Reverse Inquiry Transactions Settlement

Structured Thoughts -- Volume 4, Issue 3 -- February 6, 2013

In This Issue: Reverse Inquiry Transactions in the Spotlight; How Will the Fed’s Proposed Foreign Bank Rules Affect Foreign Bank Debt Financing Activities in the U.S.?; IOSCO Commences Consultation on Benchmarks; and...more

2/7/2013 - Benchmarks FINRA Foreign Banks Investors IOSCO Regulation T Reverse Inquiry Transactions SEC Structured Financial Products

Structured Thoughts -- Volume 4, Issue 2 -- January 24, 2013: IOSCO Publishes Suitability Requirements for Distribution of Complex...

On January 21, 2013, the International Organization of Securities Commissions (IOSCO), of which the Financial Industry Regulatory Authority, Inc. is an affiliate member, published its final report on Suitability Requirements...more

1/24/2013 - Complex Financial Products EU FINRA IOSCO MiFID Suitability Requirements

OCC Regulations Affecting Bank Note Offerings Become Effective

On January 1, 2013, the new regulations of the Office of the Comptroller of the Currency (the “OCC”) amending Part 16.6 of the OCC’s securities offering rules became effective. These rules govern the exemption from OCC...more

1/23/2013 - Bank Notes Dodd-Frank Exemptions OCC Registration

Structured Thoughts -- Volume 4, Issue 1 -- January 16, 2013

In This Issue: Additional SEC Guidance on Estimated Value Disclosures; FINRA to Continue Its Focus on Structured Products; FINRA’s Ketchum Discusses Structured Products; FINRA Issues Q&A Guidance on New Communications...more

1/17/2013 - Estimated Value Disclosures ETFs ETNs Executive Compensation FINRA Prospectus SEC

Structured Thoughts -- Volume 3, Issue 14 -- December 18, 2012

In This Issue: Dividend Adjustments on the Way; Federal Court Decision Supports Use of “Big-Boy Letters”; FINRA Updates Its Suitability Questions and Answers; FINRA Rule 5123 Excludes Some, But Not All, Options;...more

12/19/2012 - Big-Boy Letters Commodity Pool Dividends ETFs FINRA Fiscal Cliff GFMA

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