FINRA's Take On Internal Communications

Law360, New York (February 18, 2010, 4:20 PM EST) -- The Financial Industry Regulatory Authority recently brought four disciplinary actions that have the effect of imposing upon broker-dealers the obligation to ensure that internal-use-only materials contain the same cautions and disclaimers as pieces used with the public. Such an obligation is new.

Because the imposition of this obligation would have far-reaching consequences on compliance practice, the industry as well as the regulatory process would be better served through rulemaking, including the notice and comment procedure, rather than imposing this obligation through enforcement actions.

In fact, just...
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