Guidance

FINRA Chairman and CEO Rick Ketchum, Lead Governor Jack Brennan and Finance Committee Chairman Jim Weddle review rulemaking and other issues discussed at FINRA's December Board of Governors meeting. In addition to the video, a summary of the board actions is also available.

FINRA webinars are free, online video programs delivered right to your desktop. Webinars include panel discussions with FINRA staff and/or industry experts, and feature online resource materials that participants can access from their own computers.

FINRA is committed to ensuring that all respondents are treated fairly in the disciplinary process. Below, you will find brief answers to a number of questions frequently asked by respondents. We hope these answers will be helpful in orienting you to the disciplinary process.

FINRA Chairman and CEO Rick Ketchum is joined by lead governor Jack Brennan to review rulemaking and other issues discussed at FINRA's July 2015 Board of Governors meeting.

What is a Fast Track Review?

In mid-2013, the Membership Application Program (“MAP”) Group designated a dedicated front-line team of examiners (the “Triage Group”) to conduct an initial assessment of each New Member Application, Continuing Membership Application, Materiality Consultation, Membership Agreement Change and Two Principal Waiver.

February 20, 2015

Mr. Gregory J. Nowak
Pepper Hamilton LLP
3000 Two Logan Square
Eighteenth and Arch Streets
Philadelphia, PA 19103-2799

Re: FINRA Rule 5130 - Restrictions on the Purchase and Sale of Initial Equity Public Offerings

Dear Mr. Nowak:

This is in response to your letter dated December 3, 2014, in which you request interpretive guidance on behalf of PCV Lux, SCA ("PCV") regarding the definition of "portfolio manager" under FINRA Rule 5130(i)(10)(D) (Portfolio Managers).

1. Q: If I am an existing subscriber or vendor of the SPDS (Structured Products Dissemination Service) will I automatically receive the new ABS data set on June 1, 2015?
   A: Existing subscribers or vendors of SPDS will automatically receive disseminated transactions in publicly traded ABS. No changes to the vendor agreement are required. Please note: Rule 144A ABS transactions will be disseminated over the SPDS144A feed, which requires a subscription to the 144A data set.
   

What is a Materiality Consultation?

Pursuant to NASD Rule 1017(a)(5), a member firm that plans to undergo a material change in business operations is required to file a Continuing Membership Application (“CMA”) with FINRA’s Membership Application Program (“MAP”) Group prior to implementing the material change.

FINRA Rule 2360(b)(2) provides that “[t]he position and exercise limits for FLEX Equity Options for members that are not also members of the exchange on which FLEX Equity Options trade shall be the same as the position and exercise limits as applicable to members of the exchange on which such FLEX Equity Options are traded.”