On June 23, 2011, the SEC issued Release No. 34-64736 concerning FINRA’s rule filing to adopt FINRA Rule 3110 (Supervision) and FINRA Rule 3120 (Supervisory Controls) and certain related rules. These rule changes are intended to consolidate existing NASD and NYSE rules and guidance relating to supervision and supervisory controls of member firms into FINRA rules. Although many of the consolidated provisions are identical or nearly identical to those in the original rules, there are some substantive changes, including new guidance in Supplementary Material appended to the end of Rule 3110. A table prepared by Goodwin Procter showing the origins of the consolidated rule provisions and discussing substantive changes is available here.
Alert June 29, 2011