This week, on Thursday, August 25, 2016, the SEC approved FINRA Proposed Rules 2030 and 4580 (the Proposed Rules) as they had been proposed by FINRA. The Proposed Rules would impose pay-to-play restrictions and recordkeeping requirements on broker-dealers that act as placement agents for investment advisers or their managed funds. Our December 24, 2015, mailing summarized the Proposed Rules.

FINRA is required within the next two months to issue a release setting the effective date for the Proposed Rules. That effective date must be between six months and one year following FINRA’s release. Thus, depending on FINRA’s next step, the Proposed Rules will take effect between late February 2017 and late October 2017. We will continue to keep you informed of any updates.

View FINRA’s August 25 order.

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.

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