On October 17, 2012, the SEC approved changes to NASD Rule 2711, as administered by the Financial Industry Regulatory Authority (FINRA), and NYSE Rule 472, to bring both rules into compliance with the JOBS Act mandate to eliminate research quiet period restrictions with respect to emerging growth companies (EGCs) and liberalize analyst participation in pitch meetings for initial public offerings (IPOs) by EGCs. The rule changes largely are consistent with the Frequently Asked Questions (FAQ) posted by the SEC’s Division of Trading and Markets on August 22, 2012.
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