ARTICLE
24 May 2017

FINRA T+2 Rules Are Approved

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Morrison & Foerster LLP

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In order to coincide with the effective date for the revisions to SEC Rule 15c6-1(a), these amendments will become effective on September 5, 2017, and relate to the following FINRA rules:...
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In May 2017, in Regulatory Notice 17-19, FINRA announced the SEC approval of a variety of its proposed rule amendments relating to the upcoming move of the U.S. securities markets to the T+2 settlement cycle.

In order to coincide with the effective date for the revisions to SEC Rule 15c6-1(a), these amendments will become effective on September 5, 2017, and relate to the following FINRA rules:

  • Rule 2341 (Investment Company Securities);
  • Rule 11140 (Transactions in Securities ''Ex-Dividend,'' ''Ex-Rights,'' or ''Ex-Warrants'');
  • Rule 11150 (Transactions ''Ex-Interest'' in Bonds Which Are Dealt in ''Flat'');
  • Rule 11210 (Sent by Each Party);
  • Rule 11320 (Dates of Delivery) (this provision includes the definition of "Regular Way," and refers to the new two business day delivery cycle);
  • Rule 11620 (Computation of Interest);
  • Rule 11810 (Buy-In Procedures and Requirements); and
  • Rule 11860 (COD Orders).

We previously discussed these amendments in December 2016, at the time of their proposal.

FINRA has also issued an investor alert, entitled "T+2 is Coming," to help explain to investors the impact of the upcoming market-wide changes.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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