• FINRA Piles It On: Private Placements to Wealthy Individuals Trigger FINRA Filing Requirements
  • October 22, 2012 | Authors: Michael T. Campoli; Bertrand C. Fry; Stephen M. Goodman
  • Law Firm: Pryor Cashman LLP - New York Office
  • Beginning December 3, 2012, when a member of the Financial Industry Regulatory Association (“FINRA”) acts as placement agent for a non&member issuer that is conducting a private placement of its securities, the member will be required, in many instances, to file the issuer’s private placement memorandum, term sheet, or other offering documents with FINRA within 15 days after the date of the first sale by such member of the offered securities, or to indicate to FINRA by a notice filing that no offering documents were used. This is the latest in a series of notices that reflect FINRA’s increasing concern with the private placement process and, as discussed below, is likely to have particular impact on private placements targeting non&institutional accredited investors.