Structured Thoughts - Volume 1, Issue 17 - December 2010

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In this issue: A Summary of FWP Filing Requirements Under SEC and FINRA Rules; SEC Proposes to Extend Effectiveness of Rule 206(3)-3T.

Introduction: In October 2010, FINRA released its Regulatory Notice 10-52. Notice 10-52, among other things, applies FINRA’s filing and related requirements set forth in NASD Rule 2210 to broadly disseminated FWPs used by broker-dealers.

Market participants have now been reminded of the applicability of the FINRA rules to FWPs. Because both the SEC’s filing rules and FINRA’s rules apply to these documents, as a brief reference guide we have prepared the following summary of their respective rules. These rules frequently come into play in connection with FWPs prepared for different types of structured products.

Please see full publication below for more information.

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