• FINRA Reverses Course and Issues Guidance Changing Its Interpretation Regarding the Key Issues of "Potential Investors" and Non-Security Recommendations
  • December 20, 2012 | Authors: Clifford E. Kirsch; Susan S. Krawczyk; S. Lawrence Polk; Brian L. Rubin
  • Law Firms: Sutherland Asbill & Brennan LLP - New York Office ; Sutherland Asbill & Brennan LLP - Washington Office ; Sutherland Asbill & Brennan LLP - Atlanta Office ; Sutherland Asbill & Brennan LLP - Washington Office
  • FINRA’s new suitability requirement, Rule 2011, went into effect July 9, 2012. Because the rule was such a departure from prior standards, FINRA issued Regulatory Notice 12-25 (May 2012) to explain the rule and to clarify its implications. In an unusual regulatory do-over, on December 10, 2012, less than six months after the effective date of the rule, FINRA issued Regulatory Notice 12-55 (December 2012) changing its interpretation regarding certain key issues. View the full RN 12-55.