Burr Alert: Proposed FINRA Rules Governing Markups, Commissions And Fees


Through its recent Regulatory Notice 13-07, the Financial Industry Regulatory Authority ("FINRA") announced and sought comments on its proposed amendments to rules governing markups, markdowns, commissions and fees associated with brokered investment transactions. This was the second solicitation for comments sought by FINRA for these rules, the first announced in Regulatory Notice 11-08. FINRA received 25 comment letters in response to Regulatory Notice 11-08 and subsequently sought comment on the additional revisions made in light of these letters.

FINRA's proposed amendments dealt with the "markup rules": (1) FINRA Rule 2121 on Fair Prices and Markups, Markdowns and Commissions, (2) FINRA Rule 2122 on Markups and Markdowns for Transactions in Debt Securities, Except Municipal Securities, and (3) FINRA Rule 2123 on Charges and Fees for Services Performed. Initially, in Regulatory Notice 11-08, FINRA proposed significant and substantive changes to the policies governing markups, markdowns and the information provided customers regarding commissions. But based on commenters' overwhelmingly negative feedback on these amendments, FINRA revised its proposals to make fewer dramatic changes.

Please see full Alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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