Structured Thoughts -- Volume 3, Issue 8 May 30, 2012


In This Issue:

FINRA’s New Guidance Relating to Suitability – Potential Impact on Structured Products; FINRA’s Consent Agreements Target Supervisory Systems and Procedures in the Sale of Non-Traditional ETFs; and Massachusetts Fines Broker Dealer for Sales of Non-Traditional ETFs

Excerpt from FINRA’s New Guidance Relating to Suitability – Potential Impact on Structured Products

On May 21, 2012, FINRA issued Regulatory Notice 12-25, in which FINRA provided additional guidance on its new suitability rule, FINRA Rule 2111...

The additional guidance responds to industry questions about Rule 2111. Some of the additional guidance applies to sales practices in the structured products industry; we discuss that guidance below. The new notice reminds the industry that many of the obligations under the new suitability rules are the same as under the predecessor rules. However, the new Q&A’s provide some useful indications of FINRA’s views on a variety of questions that brokers frequently must address.

Please see full issue below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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