The U.S. Financial Industry Regulatory Authority (“FINRA”) recently issued Regulatory Notice 12-09, requesting comments to a revised concept proposal to regulate fixed-income research reports (the “Revised Proposal”). The Revised Proposal follows a concept proposal that was first released in March 2011 (the “Concept Proposal”), which proposed substantive regulation and disclosure requirements for fixed-income research through a “tiered” approach that generally would establish a regulatory regime for fixed-income research that is highly analogous to that which is in place for equity research. While the Revised Proposal retains this tiered approach, FINRA has incorporated several changes to its original concept based on comments from industry participants. FINRA now seeks comments on the Revised Proposal, the comment period for which is set to expire on April 2, 2012.
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