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Revolving Door Rules
FINRA’s “Revolving Door Rules” restrict former FINRA officers and employees from making communications to or appearances before FINRA in certain situations. The purpose of these FINRA Rules—and internal corporate policies covering employees’ interactions with former FINRA colleagues—is to mitigate the appearance of conflicts of interest that occur when former officers and employees appear before or communicate with FINRA (through meetings, conference calls, written communications or otherwise) with the intent to influence FINRA’s decisions and actions.
FINRA Rules 9910(a), (b) and (c) are modeled after relevant portions of the federal government’s regulations setting forth post-employment restrictions applicable to former government employees, as contained in 5 C.F.R. Part 2641, which interprets the federal ethics law on post-employment conflicts (18 U.S.C. § 207). Rule 9910(d) covers obligations of confidentiality owed by current and former employees and codifies existing confidentiality obligations. FINRA Rules 9141(b) and 9242(c), already in existence, prohibit former FINRA officers from making an appearance before a FINRA adjudicator or providing expert testimony on behalf of any other party for a period of one year after their departure from FINRA.
The 9910 series rules are effective as of different dates, as noted in the rule filing.
For former employees who are attorneys, the relevant rules of professional responsibility also govern their post-FINRA employment activities.
The following Revolving Door Frequently Asked Questions are designed to explain the general application of these FINRA Rules. No single document can address every potential situation. If you have questions about the Revolving Door Rules or their application, please contact the FINRA Support Center at (301) 590-6500 for guidance regarding your particular circumstances.
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