Regulation M Filings
As part of FINRA's program to monitor firms for compliance with the SEC's Regulation M, FINRA's Market Regulation department reviews over-the-counter (OTC) trading and quoting activity for prohibited purchases, bids or attempts to induce bids or purchases during the applicable restricted period, and for prohibited short sales during the five-day period prior to pricing the offering. Pursuant to its rules, FINRA must receive pertinent distribution-related information in a timely fashion to facilitate this component of its Regulation M compliance program.
Firms are reminded that in addition to the Regulation M-related reporting requirements under FINRA rules, discussed in detail in Regulatory Notice 08-74, they may have other reporting obligations, e.g., under the FINRA transaction reporting rules or the Regulation M-related rules of a national securities exchange.
Filing Regulation M Forms
Firms must use the following forms to satisfy their reporting obligations under FINRA Rules 5190 and 6275. Firms must submit an amended form to update information previously provided, as necessary.
- Underwriting Activity Report Request Form (PDF 28 KB)
- Regulation M Restricted Period Notification Form (PDF 36 KB)
- Regulation M Notice of Intent to Impose a Penalty Bid, Engage in a Syndicate Covering Transaction and/or Enter a Stabilizing Bid (PDF 28 KB)
- Regulation M Trading Notification Form (PDF 32 KB)
Filing Forms Under FINRA Rule 5190
Firms must submit all compliance forms under Rule 5190 to Market Regulation via:
- Email to secondaryofferings@finra.org;
- Fax to (301) 339-7403; or
- A third-party vendor (e.g., Dealogic, Ipreo).
Filing Forms Under FINRA Rule 6275
Firms must submit all compliance forms under Rule 6275 to ADF Operations via email to FINRAOperations@finra.org or fax to (240) 386-6225 and Market Regulation via:
- Email to secondaryofferings@finra.org;
- Fax to (301) 339-7403; or
- A third-party vendor (e.g., Dealogic, Ipreo).
If you have questions about these submissions or about other Regulation M-related issues, please review related frequently asked questions or call (240) 386-5560.
