Beginning December 3, 2012, FINRA members will have to file with FINRA any offering documents used to conduct any private offering in which the member acts as placement agent unless there is an available exemption. Alternatively, if no offering documents are being used, the member must notify FINRA to that effect. This new rule represents another step in the efforts by FINRA and the SEC to tighten regulation of the private placement market and will particularly impact offerings by issuers (including private investment funds) to “accredited investors” who are individuals.