Structured Thoughts - Volume 2, Issue 10 - July 27, 2011

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In this issue: FINRA’s Proposed Revisions to Rule 2210, Communications with the Public: Expected Impact on the Structured Products Market; FINRA Warns Investors About Chasing Returns in Structured Products and Other Investments; and State of Georgia Reviewing Offerings of Reverse Convertible Notes.

In July 2011, FINRA proposed to amend several of its rules relating to broker-dealers’ communications with the public. These rules relate to a number of areas, and potentially impact a wide variety of securities offerings. In this article, we address the potential impact of these proposals on offerings of structured products, and the documents used in these transactions.

The rules were initially proposed for amendment in September 2009. FINRA’s revised proposal reflects, among other things, a variety of comments that it received from industry participants. The proposals also reflect FINRA’s continuing interest in offering activities relating to the structured products market.

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