Structured Thoughts -- Volume 3, Issue 3 March 21, 2012



*FINRA Priorities

*Know Your Distributor

*Best Execution

Excerpt from FINRA Priorities

FINRA’s annual letter to member firms regarding its 2012 regulatory and examination priorities included a number of issues relating to structured products. In its letter, FINRA notes that it will focus on evidence of “yield chasing.” Also, it will consider the suitability of certain complex products (including products for which there is a limited secondary market and products for which the cash flows may be difficult to predict). Continuing the themes stated in recent Regulatory Notice 12-03, FINRA highlights a number of products as to which there are heightened concerns regarding suitability and potential misselling. These include exchange-traded products that use sophisticated trading strategies and structured products.

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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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