On October 11, 2012, the Financial Industry Regulatory Authority (“FINRA”) issued a revised proposal to address debt research conflicts of interest that includes amending proposed exemptions for research distributed to certain institutional investors and for firms with limited principal debt trading activity. The revised proposal also includes other changes in response to comments on a prior proposal set forth in Regulatory Notice 12-09.

This alert summarizes the proposed exemptions and rule changes found in FINRA’s Regulatory Notice 12-42.