FINRA Introduces Two Fixed Income Initiatives


The Financial Industry Regulatory Authority, Inc. (FINRA) introduced two new initiatives related to the fixed income markets. FINRA proposed to establish a central depository for the public dissemination of new issue corporate bond reference data and to publish aggregated transaction information on U.S. Treasury Securities. The Securities and Exchange Commission (SEC) approved both proposals in December 2019. FINRA plans to begin publishing aggregated transaction data for U.S. Treasury Securities on March 10, 2020. The SEC, however, subsequently stayed the approval of the corporate bond depository until further notice. 

FINRA’s New Issue Reference Data Service for Corporate Bonds

On March 27, 2019, FINRA filed with the SEC a proposed rule change to establish a new issue reference data service for corporate bonds.1 FINRA’s proposal was in line with the SEC’s Fixed Income Market Structure Advisory Committee’s (FIMSAC) recommendation that the SEC, in conjunction with FINRA, establish a reference data service for corporate bonds which would contain specified data elements on corporate bond new issues that are eligible for FINRA’s Trade Reporting and Compliance Engine (TRACE).2

FINRA proposed to amend FINRA Rule 6760 to require that underwriters subject to Rule 6760 report to FINRA a number of data elements for new issues in Corporate Debt Securities.3 Specifically, Proposed Rule 6760(b)(2) would require that, in addition to the information required by Rule 6760(b)(1), for a new issue in a Corporate Debt Security, excluding bonds issued by religious organizations or for religious purposes, the following information must be reported, if applicable: (1) the International Securities Identification Number (ISIN), (2) the currency, (3) the issue date, (4) the first settle date, (5) the interest accrual date, (6) the day count description, (7) the coupon frequency, (8) the first coupon payment date, (9) a Regulation S indicator, (10) the security type, (11) the bond type, (12) the first coupon period type, (13) a convertible indicator, (14) a call indicator, (15) the first call date, (16) a put indicator, (17) the first put date, (18) the minimum increment, (19) the minimum piece/denomination, (20) the issuance amount, (21) the first call price, (22) the first put price, (23) the coupon type, (24) rating (TRACE Grade), (25) a perpetual maturity indicator, (26) a Payment-In-Kind (PIK) indicator, (27) first conversion date, (28) first conversion ratio, (29) spread, (30) reference rate, (31) floor, and (32) underlying entity ticker. Underwriters would be required to report all data fields for Corporate Debt Securities prior to the first transaction in the security. 

FINRA proposed to disseminate this collected reference data upon receipt, and provide subscribers with access to the data for a fee.4 FINRA intended to implement the service after it submitted and received approval for fees related to the new issue reference data service. The proposal received 28 comment letters as well as a response to commenters from FINRA.5

On December 4, 2019, the SEC, pursuant to delegated authority, approved FINRA’s proposal.6 In support of its approval order, the SEC stated that, contrary to certain comments it received, it believed that FINRA had provided sufficient justification under the Exchange Act for its proposal, and that there was evidence of market structure problems that require regulatory intervention. The SEC agreed with FINRA that a gap currently exists in the market of newly issued corporate bond reference data, namely, the lack of broadly available and accessible new issue reference data on the first day of secondary market trading, and that this gap can impede efficiency and competition in the current marketplace. The SEC concluded that FINRA’s proposal was reasonably designed to address this regulatory gap in the current market to the benefit of the marketplace. Furthermore, in response to commenters raising concerns regarding increased burdens on underwriters due to the new reporting requirements, and on small underwriters in particular, the SEC stated that such burdens would be limited. Commenters also raised concerns that the proposal would diminish competition among private sector reference data providers by displacing existing for-profit competition with a regulator-provided service. In response, the SEC stated that the limited set of data proposed to be reported and disseminated to allow for the identification, valuation and settlement of new issue corporate bonds would not supplant the demand for a more comprehensive reference database with enhanced data sets that contain additional fields not reported to or disseminated by FINRA. Finally, commenters objected to FINRA’s postponement of the filing of the proposed fees for the new service, warning that separating the fee proposal into a subsequent filing would allow FINRA to avoid regulatory and public scrutiny of the proposed fees. The SEC disagreed with this concern, noting that FINRA cannot charge fees for the proposed data service until the SEC receives a proposed rule change that complies with the Exchange Act and SEC rules concerning proposed fee changes.

On December 12, 2019, however, the SEC stayed the delegated approval of the service until the SEC determines otherwise.7 On December 18, 2019, Bloomberg, L.P., filed with the SEC a Petition for Review of the approval of FINRA’s new issue reference data services for corporate bonds.8 In its petition, Bloomberg argued that FINRA’s proposal was an attempt to replace bond reference data that competitive private vendors currently offer in the marketplace with a regulatory utility.

FINRA’s Publication or Distribution of Aggregated Transaction Information and Statistics on U.S. Treasury Securities

On December 20, 2019, the SEC approved FINRA’s proposal to publish aggregated transaction information and statistics on U.S. Treasury Securities.9 With this approval, FINRA will expand the securities for which it publicly disseminates transaction information to include certain TRACE-Eligible Securities10 that are U.S. Treasury Securities.11 Starting March 10, 2020, the new aggregated TRACE data will be published on FINRA’s website.12

As described in its rule filing, FINRA amended Supplementary Material .01 to FINRA Rule 6750 to provide that FINRA may publish or distribute weekly aggregated transaction information and statistics on non-disseminated TRACE-Eligible Securities that are U.S. Treasury Securities. The aggregated U.S. Treasury Securities data would not be published or distributed by individual security,13 nor would it identify individual market participants or transactions. FINRA will provide the aggregated data on U.S. Treasury Securities at no charge, unless FINRA first establishes a fee for such data by submitting an appropriate rule filing to the SEC. 

In its approval order, the SEC noted that there is no comprehensive source of aggregated volume data that reflects all major segments of the market for U.S. Treasury Securities. Accordingly, the SEC stated that the proposal would benefit investors and market participants by facilitating greater transparency in the U.S. Treasury Security market by making publicly available aggregate trading volume for transactions in U.S. Treasury Securities that are reported to TRACE. The SEC further noted that FINRA’s proposal is reasonably designed to preserve the confidentiality of individual market participants and transactions, and would not impose any new cost on FINRA members, because any aggregate statistics that are published or distributed by FINRA pursuant to this rule change would be derived from information that members are already required to report to TRACE. The Treasury Department indicated it was supportive of FINRA’s proposal.

On February 10, 2020, FINRA announced that it would commence making Weekly Aggregated Reports of the U.S. Treasury Security data available on its website ( beginning March 10, 2020.14 The first report will contain information for the February 29 through March 7 period. The reports will illustrate trading volume in U.S. Treasury Securities reported to TRACE for the prior week. The information will be aggregated by security subtype: Bills, Floating Rate Notes (FRN), Nominal Coupons, and Treasury Inflation-Protected Securities (TIPS). The data will be further grouped into “ATS and Interdealer,” “Dealer-to-Customer” and “Total” categories. For Nominal Coupons and TIPS, the report will also show remaining maturity and on-the-run/off-the-run groupings.15   

Next Steps

The implementation of FINRA’s transparency proposal for U.S. Treasury Securities and its proposal to create a new reference data service for corporate bonds are both in an area of increasing interest to the securities regulators. For example, FINRA also has sought comment on a proposal to expand the alternative trading system (ATS) volume data that it publishes on its website to include information on transactions in corporate bonds and agency debt securities that occur within an ATS and are reported to TRACE.16 In addition, the SEC has recently renewed the charter for FIMSAC for another year to permit further exploration of issues in the fixed income markets.17 

Footnotes - 

  1. The SEC published notice of filing of the proposed rule change in the Federal Register on April 8, 2019. Securities Exchange Act Rel. No. 85488 (April 2, 2019), 84 Fed. Reg. 13977 (April 8, 2019) (“Reference Data Service Notice”). On May 22, 2019, the SEC designated a longer period within which to approve the proposed rule change, disapprove the proposed rule change, or institute proceedings to determine whether the proposed rule change should be disapproved. Securities Exchange Act Rel. No. 85911 (May 22, 2019), 83 Fed. Reg. 24839 (May 29, 2019). On July 1, 2019, the SEC instituted proceedings under Section 19(b)(2)(B) of the Securities Exchange Act of 1934 (“Exchange Act”) to determine whether to approve or disapprove the proposed rule change. Securities Exchange Act Rel. No. 86256 (July 1, 2019), 84 Fed. Reg. 32506 (July 8, 2019). On October 3, 2019, FINRA filed partial Amendment No. 2 to the proposed rule change. Amendment No. 2 is available at: On October 4, 2019, the SEC published notice of Amendment No. 2 to the proposed rule change and designated a longer period for SEC action on the proceedings to determine whether to approve or disapprove the proposed rule change. Securities Exchange Act Rel. No. 87232 (Oct. 4, 2019), 84 Fed. Reg. 54712 (October 10, 2019).
  2. See FIMSAC Recommendation for the SEC to Establish a New Issue Reference Data Service for Corporate Bonds (October 29, 2018) (available at FIMSAC was founded to provide the SEC with diverse perspectives on the structure and operations of the U.S. fixed income markets as well as advice and recommendations on matters related to fixed income market structure.
  3. FINRA proposed to move the definition of “Corporate Debt Security,” which is currently located in FINRA Rule 2232 (Customer Confirmations), into the TRACE Rule Series (specifically Rule 6710 (Definitions)) and to make corresponding technical edits to FINRA Rule 2232.
  4. FINRA originally proposed to make the corporate bond new issue reference data available to any person or organization for a fee of $250 per month for internal purposes only, and for a fee of $6,000 per month where the data is retransmitted or repackaged for delivery and dissemination to any outside person or organization. See Reference Data Service Notice at 13979. FINRA withdrew these proposed fees in Amendment No. 2.
  5. Comments are available at
  6. Securities Exchange Act Rel. No. 87656 (Dec. 4, 2019), 84 Fed. Reg. 67491 (Dec. 10, 2019).
  7. Letter from J. Matthew DeLesDernier, Assistant Secretary, SEC, to Stephanie Dumont, Senior Vice President and Director of Capital Markets Policy, FINRA re: Order Granting Approval of a Proposed Rule Change, as Modified by Amendment No. 2, to Establish a Corporate Bond New Issue Reference Data Service, Securities Exchange Act of 1934, Release No. 87656 (December 4, 2019) (Dec. 12, 2019) (available at
  8. In the Matter of the Application of Bloomberg, L.P. (Dec. 18, 2019) (available at
  9. Securities Exchange Act Rel. No. 87837 (Dec. 20, 2019), 84 Fed. Reg. 71986 (Dec. 30, 2019).
  10. FINRA Rule 6710(a) defines a “TRACE-Eligible Security” as a debt security that is U.S. dollar-denominated and is: (1) issued by a U.S. or foreign private issuer, and, if a “restricted security” as defined in Securities Act of 1933 Rule 144(a)(3), sold pursuant to Securities Act of 1933 Rule 144A; (2) issued or guaranteed by an Agency, as defined in FINRA Rule 6710(k) or a Government-Sponsored Enterprise as defined in FINRA Rule 6710(n); or (3) a U.S. Treasury Security, as defined in FINRA Rule 6710(p). “TRACE-Eligible Security” does not include a debt security that is issued by a foreign sovereign or a Money Market Instrument, as defined in FINRA Rule 6710(o).
  11. “U.S. Treasury Security” means a security, other than a savings bond, issued by the U.S. Department of the Treasury (Treasury Department) to fund the operations of the federal government or to retire such outstanding securities. The term also includes separate principal and interest components of a U.S. Treasury Security that have been separated pursuant to the Separate Trading of Registered Interest and Principal of Securities (STRIPS) program operated by the Treasury Department. See FINRA Rule 6710(p).
  12. FINRA to Publish Weekly Aggregated Reports and Statistics for U.S. Treasury Securities, FINRA Announcement (Feb. 10, 2020) (available at (“FINRA Announcement”).
  13. FINRA noted one exception to this requirement: FINRA may provide aggregated data that includes on-the-run U.S. Treasury Securities that may have had only one on-the-run security during the aggregated period.
  14. FINRA Announcement.
  15. Id. See also Securities Exchange Act Rel. No. 87540 (Nov. 14, 2019), 84 Fed. Reg. 64147 (Nov. 20, 2019).
  16. FINRA Regulatory Notice 19-22 (Sept. 23, 2019).
  17. See FIMSAC Charter (Nov. 13, 2019) (available at

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.

© WilmerHale | Attorney Advertising

Written by:


WilmerHale 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:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.