Structured Thoughts: News for the financial services community - Volume 1, Issue 13 - October 2010



Suitability Update………page 1; Ratings Update…………page 2; Basel III………….………page 2; Structured Certificates of Deposit: A Primer………page 3

Suitability Update

In connection with its continuing process of reconciling regulations as part of the FINRA consolidated rulebook, FINRA had proposed changes to FINRA Rule 2090, the know your customer rule, and Rule 2111, the suitability rule. In late August 2010, the final proposed rules were published for comment and the comment period closed last month.

The final proposed rules would implement a number of changes. Suitability determinations would apply to recommended investment strategies, not only to recommendations relating to specific securities. There are three elements or components of suitability identified by the rule: reasonable basis suitability, customer specific suitability and quantitative suitability. In considering quantitative suitability, the broker-dealer should make a determination that a series of transactions, when viewed together, would be considered suitable for the client.

Please see full newsletter below for more information.

LOADING PDF: If there are any problems, click here to download the file.

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.

© Morrison & Foerster LLP | Attorney Advertising

Written by:


Morrison & Foerster LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.