In This Issue:

- FINRA Requests Comments on Proposed Amendments to Rule 2210 and Issues Additional FAQs

- FINRA’s Revised Sanction Guidelines

- A Uniform Fiduciary Duty Standard and the Structured Products Market

- FINRA and CARDS

- The SEC, Structured Products, Disclosure, and Retail Investors

- SEC Division of Market Regulation Request for Comment Discusses Exchange-Traded Products

- Excerpt from FINRA Requests Comments on Proposed Amendments to Rule 2210 and Issues Additional FAQs:

In May 2015, FINRA issued Regulatory Notices 15-16 and 15-17, both relating to Rule 2210, Communications with the Public. The notices are a result of FINRA’s retrospective review of Rule 2210.1 Notice 15-16 contains a number of proposed amendments to Rule 2210.2 Notice 15-17 provides additional guidance, in the form of nine new Rule 2210 FAQs.3 The proposed amendments and the new FAQs cover a number of areas, a few of which are of particular interest to member firms selling structured products.

Proposed Amendments Designed to Broaden Exclusions from the Filing Requirements -

Current Rule 2210(c)(1)(A) requires new member firms to file with the FINRA advertising department any retail publication that is published or used in any electronic or other media at least 10 business days prior to first use. A proposed amendment responds to concerns that FINRA reviews of member firms’ websites unnecessarily delay firms’ abilities to communicate with the public, without providing any counterbalancing investor benefit. The proposed amendment would require the filing of a firm’s website and material changes to the website within 10 business days after first use during the one-year period after the firm’s registration with FINRA’s Central Registration Depository system.