Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Notice of Filing of Amendment No. 4 and Order Granting Accelerated Approval of a Proposed Rule Change, as Modified by Amendment Nos. 1 Through 4, Relating to the Prohibition of Certain Abuses in the Allocation and Distribution of Shares in Initial Public Offerings (“IPOs”), 61541-61547 [2010-24899]
Download as PDF
Federal Register / Vol. 75, No. 192 / Tuesday, October 5, 2010 / Notices
file number should be included on the
subject line if e-mail is used.
To help the Commission process and
review your comments more efficiently,
please use only one method. The
Commission will post all comments on
the Commission’s Internet Web site
(https://www.sec.gov/rules/sro.shtml).
Copies of the submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room on official business
days between the hours of 10 a.m. and
3 p.m. Copies of such filing also will be
available for inspection and copying at
the principal offices of the Exchange.
All comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly.
All submissions should refer to File
Number SR–NASDAQ–2010–121, and
should be submitted on or before
October 26, 2010.
(‘‘NASD’’) (n/k/a the Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’))
filed with the Securities and Exchange
Commission (‘‘SEC’’ or ‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2 a
proposed rule change to adopt new
FINRA Rule 5131 (originally proposed
as NASD Rule 2712) to further and more
specifically prohibit certain abuses in
the allocation and distribution of shares
in initial public offerings (‘‘IPOs’’).
NASD amended the proposed rule
change on December 9, 2003 and August
4, 2004. On February 10, 2010, FINRA
filed with the Commission Amendment
No. 3 to SR–NASD–2003–140.3 The
Commission published the proposed
rule change, as modified by Amendment
No. 3, for comment in the Federal
Register on March 18, 2010.4 The
Commission received three comment
letters in response to the proposed rule
change.5 On July 30, 2010, FINRA
responded to the comment letters and
filed Amendment No. 4 to the proposed
rule change. The Commission is
publishing this notice and order to
solicit comments on Amendment No. 4,
and to approve the proposed rule
change, as modified by Amendment
Nos. 1 through 4, on an accelerated
basis.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.8
Florence E. Harmon,
Deputy Secretary.
a. Quid Pro Quo Allocations
Proposed FINRA Rule 5131(a) would
prohibit any member or person
associated with a member from offering
or threatening to withhold shares it
allocates of a new issue as consideration
or inducement for the receipt of
compensation that is excessive in
relation to the services provided by the
member.
[FR Doc. 2010–24897 Filed 10–4–10; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
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[Release No. 34–63010; File No. SR–NASD–
2003–140]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Amendment No. 4 and Order Granting
Accelerated Approval of a Proposed
Rule Change, as Modified by
Amendment Nos. 1 Through 4,
Relating to the Prohibition of Certain
Abuses in the Allocation and
Distribution of Shares in Initial Public
Offerings (‘‘IPOs’’)
September 29, 2010.
I. Introduction
On September 15, 2003, the National
Association of Securities Dealers, Inc.
8 17
CFR 200.30–3(a)(12).
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II. Description of Proposal
b. Prohibition on Spinning
Proposed FINRA Rule 5131(b) would
prohibit the allocation of new issue
shares to the account of an executive
officer or director of a company (1) if the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 50896
(Dec. 20, 2004), 69 FR 77804 (Dec. 28, 2004).
4 See Securities Exchange Act Release No. 61690
(March 11, 2010), 75 FR 13176 (March 18, 2010)
(‘‘Amendment No. 3’’).
5 See Letter from Jeffrey W. Rubin, Chair,
Committee on Federal Regulation of Securities,
Business Law Section, American Bar Association
(‘‘ABA’’), to Elizabeth M. Murphy, Secretary, SEC,
dated April 6, 2010; Letter from Sean Davy,
Managing Director, Corporate Credit Markets
Division, Securities Industry Financial Markets
Association (‘‘SIFMA’’), to Elizabeth M. Murphy,
Secretary, SEC, dated April 8, 2010; and Letter from
Ross M. Langill, Chairman & CEO, Regal Bay
Investment Group LLC (‘‘Regal’’), to Elizabeth M.
Murphy, Secretary, SEC, dated April 8, 2010.
61541
company is currently an investment
banking services client of the member or
the member has received compensation
from the company for investment
banking services in the past 12 months;
(2) if the member intends to provide, or
expects to be retained by the company
for, investment banking services within
the next 3 months; or (3) on the express
or implied condition that such
executive officer or director, on behalf
of the company, will retain the member
for the performance of future investment
banking services.
FINRA also proposes that members
establish, maintain and enforce policies
and procedures reasonably designed to
ensure that investment banking
personnel have no involvement or
influence, directly or indirectly, in the
new issue allocation decisions of the
member. The spinning provision would
apply to any account in which an
executive officer or director of a public
company or a ‘‘covered non-public
company,’’ or a person materially
supported by such executive officer or
director, has a beneficial interest. The
term ‘‘covered non-public company’’
would mean any non-public company
satisfying the following criteria: (i)
Income of at least $1 million in the last
fiscal year or in two of the last three
fiscal years and shareholders’ equity of
at least $15 million; (ii) shareholders’
equity of at least $30 million and a twoyear operating history; or (iii) total
assets and total revenue of at least $75
million in the latest fiscal year or in two
of the last three fiscal years.6 FINRA
also proposes to prohibit new issue
allocations only where the person
responsible for making the allocation
decision ‘‘knows or has reason to know
that the member intends to provide, or
expects to be retained by the company
for, investment banking services within
the next 3 months.’’
In addition, to facilitate compliance
with the spinning provisions as
requested by commenters, proposed
new Supplementary Material .02 would
expressly permit members to rely on
written representations obtained within
2 17
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Fmt 4703
Sfmt 4703
6 These criteria are based on quantitative initial
listing standards for a national securities exchange,
which FINRA believes is a suitable proxy for the
types of companies that are likely to be targeted by
members for investment banking services. In this
case, FINRA has determined that the applicable
standards should be no less than those required for
initial listing on the NASDAQ Global Market.
FINRA further believes that, in modifying the scope
of companies covered by the spinning provisions,
it is unnecessary to create a de minimis standard
for investment banking services compensation as
urged by ABA. Moreover, FINRA also believes that
a de minimis standard would pose additional
compliance burdens and would be susceptible to
abuse by those seeking to avoid application of the
proposed rule.
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the prior 12 months from the beneficial
owner(s) of the account (or a person
authorized to represent the beneficial
owner(s)) as to whether such beneficial
owner(s) is an executive officer or
director (or person materially supported
by an executive officer or director) and
if so, the company(ies) on whose behalf
such executive officer or director serves.
FINRA requires that the initial
representation be an affirmative
representation, but will permit such
representation to be updated annually
through the use of negative consent
letters. Finally, a member would be
required to maintain a copy of all
records and information relating to
whether an account is eligible to receive
an allocation of the new issue for at
least three years following the member’s
allocation to that account.
FINRA also proposes to include a
limitation in the spinning rule
providing that the spinning prohibitions
would not apply to allocations made to
any account described in FINRA Rule
5130(c)(1) through (3) and (5) through
(10), or to any other account in which
the beneficial interests of executive
officers and directors of the company
and persons materially supported by
such executive officers and directors in
the aggregate do not exceed 25% of such
account.7 FINRA also proposes to add a
new definition of ‘‘beneficial interest,’’
which would have the same meaning as
FINRA Rule 5130.8
FINRA proposes to use the term ‘‘new
issue’’ throughout the proposed rule and
to use the same definition provided in
FINRA Rule 5130(i)(9). Thus, the
proposed rule, as amended, would
apply to ‘‘new issues,’’ meaning ‘‘any
initial public offering of an equity
security as defined in Section 3(a)(11) of
the Act, made pursuant to a registration
statement or offering circular.’’ As such,
the proposed definition of ‘‘new issue’’
would exclude:
• Offerings made pursuant to an
exemption under Section 4(1), 4(2) or
4(6) of the Securities Act of 1933
(‘‘Securities Act’’), or Securities Act Rule
504 if the securities are ‘‘restricted
7 One commenter asked that hedge funds clearly
be included in the proposal. See Regal. FINRA
notes that hedge funds would be included where
the beneficial interest of executive officers and
directors of a particular company (and materially
supported persons) in the aggregate exceed 25%.
FINRA continues to believe that the 25% threshold
is most appropriate and therefore will not increase
the standard to 50% as requested by one
commenter. See ABA.
8 FINRA Rule 5130(i)(1) defines ‘‘beneficial
interest’’ to mean any economic interest, such as the
right to share in gains or losses. The receipt of a
management or performance based fee for operating
a collective investment account, or other fees for
acting in a fiduciary capacity, shall not be
considered a beneficial interest in the account.
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18:36 Oct 04, 2010
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securities’’ under Securities Act Rule
144(a)(3), or Rule 144A or Rule 505 or
Rule 506 adopted thereunder;
• Offerings of exempted securities as
defined in Section 3(a)(12) of the Act,
and rules promulgated thereunder;
• Offerings of securities of a
commodity pool operated by a
commodity pool operator as defined
under Section 1a(5) of the Commodity
Exchange Act;
• Rights offerings, exchange offers, or
offerings made pursuant to a merger or
acquisition;
• Offerings of investment grade assetbacked securities;
• Offerings of convertible securities;
• Offerings of preferred securities;
• Offerings of an investment company
registered under the Investment
Company Act of 1940 (‘‘Investment
Company Act’’);
• Offerings of securities (in ordinary
share form or ADRs registered on Form
F–6) that have a pre-existing market
outside of the United States; and
• Offerings of a business development
company as defined in Section 2(a)(48)
of the Investment Company Act, a direct
participation program as defined in Rule
2310(a) or a real estate investment trust
as defined in Section 856 of the Internal
Revenue Code.
c. Policies Concerning Flipping
Proposed FINRA Rule 5131(c)(1)
would prohibit members or persons
associated with a member from directly
or indirectly recouping, or attempting to
recoup, any portion of a commission or
credit paid or awarded to an associated
person for selling shares of a new issue
that are subsequently flipped by a
customer, unless the managing
underwriter has assessed a penalty bid
on the entire syndicate. Moreover,
proposed FINRA Rule 5131(c)(2) would
require, in addition to any obligation to
maintain records relating to penalty bids
under SEA Rule 17a–2(c)(1), that
members promptly record and maintain
information regarding any penalties or
disincentives assessed on its associated
persons in connection with a penalty
bid.
d. IPO Pricing and Trading Practices
(1) Indications of Interest
Proposed FINRA Rule 5131(d)(1)
would require, in a new issue, the bookrunning lead manager to provide to the
issuer’s pricing committee (or, if the
issuer has no pricing committee, its
board of directors): (1) A regular report
of indications of interest, including the
names of interested institutional
investors and the number of shares
indicated by each, as reflected in the
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Fmt 4703
Sfmt 4703
book-running lead manager’s book of
potential institutional orders, and a
report of aggregate demand from retail
investors; and (2) after the settlement
date of the new issue, a report of the
final allocation of shares to institutional
investors as reflected in the books and
records of the book-running lead
manager including the names of
purchasers and the number of shares
purchased by each, and aggregate sales
to retail investors.
(2) Lock-Up Agreements
Proposed FINRA Rule 5131(d)(2)
would require that any lock-up
agreement or other restriction on the
transfer of the issuer’s shares by officers
and directors of the issuer entered into
in connection with a new issue must
provide that such restrictions will apply
to their issuer-directed shares. It also
must provide that, at least two business
days before the release or waiver of any
lock-up or other restriction on the
transfer of the issuer’s shares, the bookrunning lead manager will notify the
issuer of the impending release or
waiver and announce the impending
release or waiver through a major news
service. The exceptions to this
notification requirement are where the
release or waiver is effected solely to
permit a transfer of securities that is not
for consideration and where the
transferee has agreed in writing to be
bound by the same lock-up agreement
terms in place for the transferor.
FINRA also is proposing new
Supplementary Material .03 to provide
that the required announcement also
may be made by another member or the
issuer (although it remains the
responsibility of the book-running lead
manager to ensure that the impending
release or waiver is properly announced
in compliance with this Rule).
(3) Returned Shares
Proposed FINRA Rule 5131(d)(3)
would require that the agreement
between the book-running lead manager
and other syndicate members must
require, to the extent not inconsistent
with SEC Regulation M, that any shares
trading at a premium to the public
offering price that are returned by a
purchaser to a syndicate member after
secondary market trading commences be
used to offset the existing syndicate
short position. If no syndicate short
position exists, proposed FINRA Rule
5131(d)(3)(B) would require the member
to either: (1) Offer returned shares at the
public offering price to unfilled
customers’ orders pursuant to a random
allocation methodology; or (2) sell
returned shares on the secondary market
and donate profits from the sale to an
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Federal Register / Vol. 75, No. 192 / Tuesday, October 5, 2010 / Notices
‘‘unaffiliated charitable organization’’
with the condition that the donation be
treated as an anonymous donation to
avoid any reputational benefit to the
member. Proposed FINRA Rule 5131
would establish a new definition of
‘‘unaffiliated charitable organization’’ to
prevent such charitable donations from
benefiting the member or executive
officers and directors of the member
(and persons they materially support).9
The definition of ‘‘unaffiliated charitable
organization’’ is closely tied to specific
information charities are required to file
with the Internal Revenue Service.
(4) Market Orders
Proposed FINRA Rule 5131(d)(4)
would require that no member may
accept a market order for the purchase
of shares of a new issue in the
secondary market prior to the
commencement of trading of such
shares in the secondary market.
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e. Definitions
Proposed FINRA Rule 5131(d) would
provide the following definitions. The
term ‘‘public company’’ would mean any
company that is registered under
Section 12 of the Exchange Act or files
periodic reports pursuant to Section
15(d) thereof. The term ‘‘beneficial
interest’’ would have the same meaning
as defined in FINRA Rule 5130(i)(1).
The term ‘‘covered security’’ would
mean any non-public company
satisfying the following criteria: (i)
Income of at least $1 million in the last
fiscal year or in two of the last three
fiscal years and shareholders’ equity of
at least $15 million; (ii) shareholders’
equity of at least $30 million and a twoyear operating history; or (iii) total
assets and total revenue of at least $75
million in the latest fiscal year or in two
of the last three fiscal years. The term
‘‘flipped’’ would mean the initial sale of
new issue shares purchased in an
offering within 30 days following the
offering date of such offering.
In addition, proposed FINRA Rule
5131(d) would define the term
‘‘investment banking services’’ to
include, without limitation, acting as an
underwriter, participating in a selling
group in an offering for an issuer or
otherwise acting in furtherance of a
9 Proposed FINRA Rule 5131(e)(9) defines
‘‘unaffiliated charatable organization’’ as a taxexempt entity organized under Section 501(c)(3) of
the Internal Revenue Code that is not affiliated with
the member and for which no executive officer or
director of the member, or person materially
supported by such executive officer or director, is
an individual listed or required to be listed on Part
VII of the Internal Revenue Service Form 990 (i.e.,
officers, directors, trustees, key employees, highest
compensated employees and certain independent
contractors).
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18:36 Oct 04, 2010
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public offering of the issuer; acting as a
financial adviser in a merger,
acquisition or other corporate
reorganization; providing venture
capital, equity lines of credit, private
investment, public equity transactions
(PIPEs) or similar investments or
otherwise acting in furtherance of a
private offering of the issuer; or serving
as placement agent for the issuer. Under
the proposed rule, the term ‘‘material
support’’ would mean directly or
indirectly providing more than 25% of
a person’s income in the prior calendar
year. Persons living in the same
household are deemed to be providing
each other with material support. The
term ‘‘new issue’’ would have the same
meaning as in Rule 5130(i)(9). In
addition, the term ‘‘penalty bid’’ would
mean an arrangement that permits the
managing underwriter to reclaim a
selling concession from a syndicate
member in connection with an offering
when the securities originally sold by
the syndicate member are purchased in
syndicate covering transactions. The
term ‘‘unaffiliated charitable
organization’’ would mean a tax-exempt
entity organized under Section 501(c)(3)
of the Internal Revenue Code that is not
affiliated with the member and for
which no executive officer or director of
the member, or person materially
supported by such executive officer or
director, is an individual listed or
required to be listed on Part VII of the
Internal Revenue Service Form 990 (i.e.,
officers, directors, trustees, key
employees, highest compensated
employees and certain independent
contractors).
Supplementary Material
Proposed FINRA Rule 5131 would
also include supplementary material
regarding issuer directed allocations, in
paragraph .01, which would provide
that the prohibitions of paragraph (b) of
the rule would not apply to securities
that are directed in writing by the
issuer, its affiliates, or selling
shareholders, so long as the member has
no involvement or influence, directly or
indirectly, in the allocation decisions of
the issuer, its affiliates, or selling
shareholders with respect to such
issuer-directed shares. Proposed FINRA
Rule 5131 would also provide
supplementary material regarding
annual representation, in paragraph .02,
which would provide that for purposes
of paragraph (b) of the rule, a member
may rely on a written representation
obtained within the prior 12 months
within the parameters set forth in
paragraph .02. The proposed rule would
also provide supplementary material
regarding lock-up announcements, in
PO 00000
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Fmt 4703
Sfmt 4703
61543
paragraph .03, stating that the
requirement that the book-running lead
manager announce the impending
release or waiver of a lock-up or other
restriction on the transfer of the issuer’s
shares shall be deemed satisfied where
such announcement is made by the
book-running manager, another member
or the issuer, so long as such
announcement otherwise complies with
the requirements of paragraph (d)(2) of
Rule 5131.
The text of the proposed rule change
is available on FINRA’s Web site at
https://www.finra.org, at the principal
office of FINRA, and at the
Commission’s Public Reference Room.
III. Summary of Comments and
Amendment No. 4
Prohibition on Spinning
Proposed FINRA Rule 5131(b) would
prohibit the allocation of IPO shares to
the account of an executive officer or
director of a company (1) if the
company is currently an investment
banking services client of the member or
the member has received compensation
from the company for investment
banking services in the past 12 months;
(2) if the member intends to provide, or
expects to be retained by the company
for, investment banking services within
the next 3 months; or (3) on the express
or implied condition that such
executive officer or director, on behalf
of the company, will retain the member
for the performance of future investment
banking services.
Commenters generally supported the
proposed changes to the spinning rule
but requested additional
modifications.10 Commenters’ concerns
included that it would be difficult to
identify the universe of officers and
directors subject to the rule and asked
that members be permitted to rely on
annual negative consent letters.11 One
commenter expressed particular
concern regarding the applicability of
the rule to officers and directors of nonpublic companies.12
In response to commenters’ concerns,
FINRA is proposing several changes to
the spinning provisions. First, FINRA
proposes that members establish,
maintain and enforce policies and
procedures reasonably designed to
ensure that investment banking
personnel have no involvement or
influence, directly or indirectly, in the
new issue allocation decisions of the
member. FINRA believes that such
procedures are essential to managing
conflicts of interest between investment
10 See
SIFMA.
ABA and SIFMA.
12 See SIFMA.
11 See
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banking and syndicate activities. FINRA
understands that these procedures are
customary at members today, and wants
to ensure that such policies and
procedures remain in force.
In addition, in response to comments,
FINRA proposes to narrow the scope of
the non-public companies covered by
the spinning provision to focus the rule
and firms’ compliance efforts on those
allocations that have the greatest
potential for abuse. Specifically, the
spinning provision would apply to any
account in which an executive officer or
director of a public company or a
‘‘covered non-public company,’’ or a
person materially supported by such
executive officer or director, has a
beneficial interest. The term ‘‘covered
non-public company’’ means any nonpublic company satisfying the following
criteria: (i) Income of at least $1 million
in the last fiscal year or in two of the
last three fiscal years and shareholders’
equity of at least $15 million; (ii)
shareholders’ equity of at least $30
million and a two-year operating
history; or (iii) total assets and total
revenue of at least $75 million in the
latest fiscal year or in two of the last
three fiscal years.13
One commenter stated that it may be
difficult to determine when the member
‘‘intends to provide’’ investment banking
services and asked that the member be
permitted to rely on policies and
procedures reasonably designed to
determine whether an entity is a current
or prospective investment banking
client, or whether the member intends
to provide investment banking services
to a prospective client, on the basis of
reasonable criteria (which criteria may
limit the identification of current clients
to those relationships that are more than
aspirational or passing, or for which the
firm has a reasonable expectation of an
active near-term relationship).14 FINRA
does not believe that the spinning
provision should be recast solely as a
‘‘policies and procedures’’ rule.
However, in response to commenters’
concerns and in light of the provision
13 These criteria are based on quantitative initial
listing standards for a national securities exchange,
which FINRA believes is a suitable proxy for the
types of companies that are likely to be targeted by
members for investment banking services. In this
case, FINRA has determined that the applicable
standards should be no less than those required for
initial listing on the NASDAQ Global Market.
FINRA further believes that, in modifying the scope
of companies covered by the spinning provisions,
it is unnecessary to create a de minimis standard
for investment banking services compensation as
urged by ABA. Moreover, FINRA believe that a de
minimis standard would pose additional
compliance burdens and would be susceptible to
abuse by those seeking to avoid application of the
proposed rule.
14 See SIFMA.
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explicitly requiring policies and
procedures excluding investment
banking personnel input into new issue
allocation decisions, FINRA proposes to
modify the three month forward looking
provision to prohibit new issue
allocations only where the person
responsible for making the allocation
decision ‘‘knows or has reason to know
that the member intends to provide, or
expects to be retained by the company
for, investment banking services within
the next 3 months.’’ FINRA believes that
this change strikes an appropriate
balance in addressing the potential that
new issue allocations will influence
future business with the member while
not unnecessarily impacting the capital
formation process.15 However,
according to FINRA, if a member
maintains effective information barriers
between the investment banking and
syndicate departments and the persons
responsible for making new issue
allocation decisions neither know nor
have reason to know of the prospective
business relationship, the forwardlooking provision will not be violated.
To facilitate compliance with the
spinning provisions as requested by
commenters, proposed new
Supplementary Material .02 expressly
permits members to rely on written
representations obtained within the
prior 12 months from the beneficial
owner(s) of the account (or a person
authorized to represent the beneficial
owner(s)) as to whether such beneficial
owner(s) is an executive officer or
director (or person materially supported
by an executive officer or director) and
if so, the company(ies) on whose behalf
such executive officer or director serves.
Consistent with current practice under
FINRA Rule 5130, FINRA requires that
the initial representation be an
affirmative representation, but will
permit such representation to be
updated annually through the use of
negative consent letters. Members are
reminded that a member may not rely
upon any representation it believes, or
has reason to believe, is inaccurate.
Finally, a member would be required to
maintain a copy of all records and
information relating to whether an
15 If an executive officer or director receives an
allocation and the investment bank subsequently is
retained for the performance of investment banking
services within the three month window by such
executive officer or director’s employing firm,
FINRA will investigate the particular information
about the business relationship that was known
(and by whom) at the time of the allocation,
including a review of the communications between
the broker-dealer and the investment banking
client, and between the investment banking and
syndicate departments, as well as the member’s
systems for logging and managing prospective and
current client and transaction information.
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Fmt 4703
Sfmt 4703
account is eligible to receive an
allocation of the new issue for at least
three years following the member’s
allocation to that account.
FINRA notes that members should
understand that the representation in
the spinning context differs from that in
FINRA Rule 5130 because, in the
spinning case, the information obtained
from the customer is not, by itself,
sufficient to make a determination of
whether a customer is eligible to
purchase a new issue. Members also
must determine whether each account
considered for a new issue allocation
involves an executive officer or director
(or materially supported person) of a
current or prospective client that falls
within the scope of paragraph (b).
Members may choose to adopt a more
restrictive internal policy prohibiting
allocations to all executive officers,
directors and materially supported
persons; however, FINRA notes that this
is not required under the proposed rule
change.16
Commenters also asked that the
definition of ‘‘account of an executive
officer or director’’ be amended to apply
to accounts in which an executive
officer, director or materially supported
person has a ‘‘beneficial interest’’ rather
than a ‘‘financial interest.’’ 17
Commenters asked that the rule exclude
accounts over which executive officers,
directors or materially supported
persons have ‘‘discretion or control’’ as
this may unduly impact allocations to
certain funds.18 Commenters further
argued that the definition of ‘‘account of
an executive officer or director’’ should
be modified to exclude certain other
entities (such as foreign investment
companies) consistent with FINRA Rule
5130(c).19
In response to comments, FINRA
proposes to delete the definition of
‘‘account of an executive officer or
director’’ and to instead include a new
limitation in the spinning rule
providing that the spinning prohibitions
would not apply to allocations made to
any account described in FINRA Rule
5130(c)(1) through (3) and (5) through
16 FINRA notes that the Voluntary Initiative more
broadly prohibited allocations to the account of any
executive officer or director of a U.S. public
company or a public company for which a U.S.
market is the principal equity trading market with
respect to all hot IPOs. Voluntary Initiative
Regarding Allocations of Securities in ‘‘Hot’’ Initial
Public Offerings to Corporate Executives and
Directors, https://www.sec.gov/news/press/
globalvolinit.htm (Apr. 28, 2003).
17 See ABA. Commenters generally favored the
use of defined terms in proposed FINRA Rule 5131
that are consistent with the terms used in Rule
5130. See ABA and Regal.
18 See ABA.
19 See ABA.
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(10), or to any other account in which
the beneficial interests of executive
officers and directors of the company
and persons materially supported by
such executive officers and directors in
the aggregate do not exceed 25% of such
account.20 As requested by commenters,
FINRA also proposes to add a new
definition of ‘‘beneficial interest,’’ which
will have the same meaning as FINRA
Rule 5130.21 FINRA believes deleting
the term ‘‘account of an executive officer
or director’’ and modifying the scope of
the rule to generally exclude those
accounts excepted from FINRA Rule
5130(c) is appropriate in that allocations
to such accounts are not likely to result
in the type of abuse the spinning
prohibition is geared toward. FINRA
believes that the proposal, as amended,
continues to meet the goals of the rule
while avoiding an unnecessary impact
on capital formation. In addition, by
replacing references to ‘‘financial
interest’’ with ‘‘beneficial interest’’ and
deleting the reference to accounts in
which officers and directors exercise
‘‘discretion or control,’’ FINRA believes
that the rule more properly focuses on
accounts in which relevant parties have
an economic interest.
Commenters argued that the spinning
rule should apply only to ‘‘hot IPOs’’ and
should exclude the types of offerings
excepted under FINRA Rule
5130(i)(9).22 FINRA does not agree that
the rule should apply only to ‘‘hot IPOs.’’
FINRA believes that the proposed rule
change should not be limited to hot
IPOs for the same reasons that FINRA
Rule 5130 is not limited to hot IPOs.23
20 One commenter asked that hedge funds clearly
be included in the proposal. See Regal. FINRA
notes that hedge funds would be included where
the beneficial interest of executive officers and
directors of a particular company (and materially
supported persons) in the aggregate exceed 25%.
FINRA continues to believe that the 25% threshold
is most appropriate and therefore will not increase
the standard to 50% as requested by one
commenter. See ABA.
21 FINRA Rule 5130(i)(1) defines ‘‘beneficial
interest’’ to mean any economic interest, such as the
right to share in gains or losses. FINRA notes that
the receipt of a management or performance based
fee for operating a collective investment account, or
other fees for acting in a fiduciary capacity, shall
not be considered a beneficial interest in the
account.
22 See ABA.
23 While earlier proposed versions of the IPO Rule
would have applied only to ‘‘hot issues,’’ FINRA,
then NASD, revised the proposal to cover the
purchase and sale of all initial equity public
offerings, not just those that open above a
designated premium, because FINRA believed the
revised approach would be easier to understand
and would avoid many of the complexities
associated with the cancellation provision. See
Securities Exchange Act Release No. 48701 (October
24, 2003), 68 FR 62126 (October 31, 2003) (Order
Approving File No. SR–NASD–99–60). (Proposed
rule change relating to restrictions on the purchases
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Specifically, the operation of a rule
based on an unknown future event—the
opening price—creates compliance
difficulties and potentially may
exacerbate spinning problems and may
harm capital formation by necessitating
members to cancel allocations and
reallocate shares to another customer.
FINRA does, however, agree that certain
types of offerings that are not likely to
trade at a premium in the aftermarket
should be excluded from the rule.
Therefore, FINRA proposes to replace
the defined term ‘‘initial public offering’’
or ‘‘IPO’’ with the term ‘‘new issue’’
throughout the proposed rule and to use
the same definition provided in FINRA
Rule 5130(i)(9). In developing the
definition of ‘‘new issue’’ in FINRA Rule
5130, FINRA carefully considered the
extent to which such offerings may be
hot issues. Thus, the proposed rule, as
amended, applies to ‘‘new issues,’’
meaning ‘‘any initial public offering of
an equity security as defined in Section
3(a)(11) of the Act, made pursuant to a
registration statement or offering
circular.’’
IPO Pricing and Trading Practices
Commenters generally supported the
amended proposal related to IPO Pricing
and Trading Practices.24 However, one
commenter asked that FINRA include
clarifying language that the lock-up
provision would only apply to lock-ups
entered into in connection with the IPO,
and not with respect to other lock-up
agreements.25 FINRA confirms that this
provision applies only to lock-up
agreements entered into in connection
with a new issue and has modified the
rule text to reflect this.26 This
commenter also asked that FINRA
clarify that the required notice of an
impending release or waiver of a lockup may be announced either by the
issuer or the applicable member(s).27
FINRA agrees that, so long as the
announcement is made through a major
news service at least two days before the
release or waiver of any lock-up or other
restriction on the transfer of the issuer’s
shares, the requirement is satisfied
irrespective of whether such
announcement is made by the bookrunning lead manager, another member
or by the issuer. Thus, FINRA is
and sales of initial public offerings of equity
securities).
24 See SIFMA.
25 See SIFMA.
26 Proposed Rule 5131(d)(2), as amended,
provides that ‘‘[a]ny lock-up agreement or other
restriction on the transfer of the issuer’s shares by
officers and directors of the issuer entered into in
connection with a new issue shall provide that
* * *’’ (new language emphasized).
27 See SIFMA.
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61545
proposing new Supplementary Material
.03 in response to comments to provide
that the required announcement also
may be made by another member or the
issuer. However, FINRA notes that it
remains the responsibility of the bookrunning lead manager to ensure that the
impending release or waiver is properly
announced in compliance with this
Rule.
One commenter argued that the rule
should be changed to permit the
syndicate to retain discretion to either
use returned shares to reduce the
syndicate position or toward unfilled
customer orders.28 FINRA does not
agree that this change is appropriate.
FINRA expects that when shares trade at
a premium to the public offering price,
the incidence of returned shares should
be minimal so as not to affect the ability
of syndicate members to stabilize the
market for such shares to the extent
stabilization activities are even
necessary. Further, FINRA believes that
the complexity of addressing this
alternative would unnecessarily
complicate the proposed rule change.29
However, in response to comments,
FINRA is amending the rule to provide
members with additional flexibility in
the handling of returned shares. The
amended proposal continues to require
that, to the extent not inconsistent with
SEC Regulation M, the agreement
between the book-running lead manager
and other syndicate members must
require that any shares trading at a
premium to the public offering price
returned by a purchaser to a syndicate
member after secondary market trading
commences be used to offset the
existing syndicate short position.30
However, where no syndicate short
position exists, the proposed rule
28 See
SIFMA.
also asked FINRA to clarify that
anonymous, ordinary course sales on a national
securities exchange or ATS at market prices will be
considered a ‘‘random allocation’’ for the purposes
of the rule. FINRA disagrees. The provision, as
previously proposed would have required that,
where no syndicate short position exists, the
member must offer the returned shares to unfilled
customer orders at the public offering price, not the
market price. Moreover, FINRA notes that, if the
shares are trading at a premium to the public
offering price, then sales by the member at market
prices would result in the premium inuring to the
benefit of the member, which is inconsistent with
the purpose of the provision and a member’s
obligations under FINRA Rule 5130.
30 One commenter asked for confirmation that the
appropriate time for determining whether returned
shares are trading at a premium to their IPO price
is at the time such securities are returned. FINRA
agrees. See SIFMA. Another commenter argued that
the requirement that members use a random
allocation methodology to reallocate returned
shares was inadequate. See Regal. FINRA disagrees
and notes that this standard is already used
successfully in other FINRA rules. See FINRA Rule
2360 (Allocation of Exercise Assignment Notices).
29 SIFMA
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change would provide the member with
the option, provided that it is in
accordance with SEC Regulation M, to
either: (1) Offer returned shares at the
public offering price to unfilled
customers’ orders pursuant to a random
allocation methodology or (2) sell
returned shares on the secondary market
and donate profits from the sale to an
‘‘unaffiliated charitable organization’’
with the condition that the donation be
treated as an anonymous donation to
avoid any reputational benefit to the
member.31 Proposed FINRA Rule 5131
establishes a new definition of
‘‘unaffiliated charitable organization’’ to
prevent such charitable donations from
benefiting the member or executive
officers and directors of the member
(and persons they materially support).
FINRA believes that charitable
donations funded by returned shares
should not provide any reputational
benefit to the member. The definition of
‘‘unaffiliated charitable organization’’ is
closely tied to specific information
charities are required to file with the
Internal Revenue Service.
The proposed rule change, as
amended, prohibits the acceptance of
market orders for the purchase of IPO
shares prior to the commencement of
trading on the secondary market. A
commenter supported the proposed
amendment but offered alternative rule
text.32 FINRA favors its existing rule
text but proposes a slight modification
in response to comments to further
clarify the provision such that the
relevant text will now state that ‘‘no
member may accept a market order for
the purchase of shares of a new issue in
the secondary market prior to the
commencement of trading of such
shares in the secondary market.’’
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Other Issues
Commenters reiterated certain
concerns regarding FINRA’s proposed
provision relating to abusive allocation
arrangements. Proposed FINRA Rule
5131(a) prohibits a member from
offering or threatening to withhold
shares it allocates in an IPO as
consideration or inducement for the
receipt of compensation that is
excessive in relation to the services
31 Proposed FINRA Rule 5131(e)(9) defines
‘‘unaffiliated charitable organization’’ as a taxexempt entity organized under Section 501(c)(3) of
the Internal Revenue Code that is not affiliated with
the member and for which no executive officer or
director of the member, or person materially
supported by such executive officer or director, is
an individual listed or required to be listed on Part
VII of Internal Revenue Service Form 990 (i.e.,
officers, directors, trustees, key employees, highest
compensated employees and certain independent
contractors).
32 See SIFMA.
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provided by the member (i.e., quid pro
quo allocations). Commenters generally
supported this proposed provision but
reiterated earlier concerns that the term
‘‘excessive’’ is subject to uncertainty.33
One commenter requested that FINRA
clarify that any services provided for a
‘‘fair price’’ as provided by FINRA’s
Corporate Financing Rule (Rule
5110(a)(9)) would not be deemed
excessive.34 This commenter also
requested guidance that any services
provided by a member paid for using
‘‘soft dollars’’ in conformity with Section
28(e) of the Act also would not be
deemed excessive.35 Another
commenter asked that clarifying
language be added to the rule to provide
that an assessment of whether
compensation is excessive would be
based on the relevant facts and
circumstances including, where
applicable, the level of risk and effort
involved in the transaction and the rates
generally charged for such services.36
As stated in Amendment No. 3,
FINRA agrees that an assessment of
whether or not compensation is
excessive would be based upon all of
the relevant facts and circumstances
including, where applicable, the level of
risk and effort involved in the
transaction and the rates generally
charged for such services.37 However,
FINRA continues to believe that the
proposed language, which refers to
‘‘compensation that is excessive in
relation to the services provided,’’ is
most appropriate in that it affords
FINRA the necessary flexibility in
addressing the range of potential quid
pro quo arrangements that may arise. As
stated in Amendment No. 3, FINRA
does not believe it is necessary to
include rule text stating that an
assessment of whether compensation is
‘‘excessive’’ will be based upon all of the
relevant facts and circumstances.38
Likewise, FINRA does not believe it is
appropriate to provide blanket guidance
regarding payments made in conformity
with Section 28(e) of the Act or FINRA
Rule 5110(a)(9).
Finally, one commenter raised
concerns regarding FINRA’s proposed
flipping provision.39 This commenter
argued that, instead of defining the
flipping period to mean the initial sale
of new issue shares within 30 days
following the offering date, the flipping
provision should be based on the sale of
33 See
ABA and SIFMA.
ABA.
35 See ABA.
36 See SIFMA.
37 See Amendment No. 3.
38 See Amendment No. 3.
39 See Regal.
34 See
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shares prior to the book manager lifting
the penalty bid, making the time period
under the rule subject to the discretion
of the managing underwriter.40 FINRA
does not agree that the suggested
alternative represents an improvement
to the proposed provision. FINRA
believes that the certainty and finality of
the proposed approach, including the
30-day window, is the appropriate
duration for prohibiting members from
recouping commissions from associated
persons whose customers sell in cases
where a penalty bid has not been
assessed on the entire syndicate.
FINRA will announce the effective
date of the proposed rule change in a
Regulatory Notice to be published no
later than 60 days following
Commission approval. The effective
date will be no less than 90 and no more
than 180 days following publication of
the Regulatory Notice announcing
Commission approval.
IV. Discussion and Commission
Findings
After carefully considering the
proposal, the comments submitted, and
FINRA’s response to the comments, the
Commission finds that the proposed
rule change, as modified by Amendment
Nos. 1 through 4, is consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
a national securities association.41 In
particular, the Commission finds that
the proposed rule change, as amended,
is consistent with Section 15A(b)(6) of
the Act,42 which requires, among other
things, that FINRA rules be designed to
prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, and, in
general, to protect investors and the
public interest. In particular, the
Commission believes that the proposed
rule change is a reasonable step to
enhance members’ avoidance of
unacceptable conduct when they engage
in the allocation and distribution of new
issue shares. The Commission also
believes that the proposed rule change
is a reasonable step to enhance public
confidence in the distribution of new
issues.
In addition, the Commission sought
specific comment in Amendment No. 3
on whether there are any alternatives to
the proposed rule change that FINRA
should consider, such as whether
proposed Rule 5131(b)’s spinning
provisions should be modified to
40 See
Regal.
approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
42 15 U.S.C. 78o–3(b)(6).
41 In
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mstockstill on DSKH9S0YB1PROD with NOTICES
include a mandatory ban prohibiting
members from seeking or providing
investment banking services to a
company for a period of 12 months
following any allocation of IPO shares to
an account of an executive officer or
director of such company and whether
such a ban would facilitate compliance.
One commenter strongly supported a
12-month prohibition.43 However,
another commenter opposed such a
prohibition, saying that it ‘‘would—by
rule—impose an automatic sanction for
even inadvertent allocations of IPO
securities’’ and ‘‘would, in all cases, be
financially disproportionate to the value
of the securities involved in any
violation, would not take into account
the specific facts of each situation,
deprive the FINRA member of its
statutory right to a fair hearing before
the imposition of any disciplinary
sanction, and would unfairly deprive
the company of the right to select the
services of the FINRA member.’’ 44
According to this commenter, in each
case, the imposition of a mandatory ban,
as suggested by the Commission, would
be an excessive penalty in light of the
facts and circumstances underlying the
potential violation of the proposed
rule.45 Nevertheless, this commenter
noted that the 12-month prohibition
‘‘should not in any event be approved
without an opportunity for review of
and comment on the text of the
proposed rule,’’ with commenter
requesting that the Commission
republish for comment any proposal to
adopt such a mandatory ban on
investment banking services with a
sixty-day comment period. In light of
these comments, the Commission will
continue to consider the commenters’
recommendations and concerns in
considering whether any future action is
warranted. However, the Commission
does not believe this issue should
preclude approval of the proposal.
V. Accelerated Approval
The Commission finds good cause,
pursuant to Section 19(b)(2) of the
Act,46 for approving the proposed rule
change, as modified by Amendment
Nos. 1 through 4 thereto, prior to the
30th day after the date or publication of
Amendment No. 4 in the Federal
Register. The changes proposed in
Amendment No. 4 respond to specific
concerns raised. Moreover, accelerating
approval of this proposal should benefit
FINRA members by aiding them in
avoiding misconduct in new issue
43 See
Regal.
ABA.
45 See id.
46 15 U.S.C. 78s(b)(2).
44 See
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distributions and should benefit
investors by taking a step to enhance
investor protection in the capital raising
process.
VI. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change, as modified by Amendment No.
4, is consistent with the Act. Comments
may be submitted by any of the
following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–NASD–2003–140 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–NASD–2003–140. This file
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal office of
FINRA. All comments received will be
posted without change; the Commission
does not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–NASD–2003–140 and
should be submitted on or before
October 26, 2010.
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61547
VII. Conclusion
It is therefore ordered pursuant to
Section 19(b)(2) of the Act, that the
proposed rule change (SR–NASD–2003–
140), as modified by Amendment Nos.
1 through 4, be, and hereby is, approved
on an accelerated basis.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.47
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010–24899 Filed 10–4–10; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–63004; File No. SR–Phlx2010–126]
Self-Regulatory Organizations;
NASDAQ OMX PHLX LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Regarding
Individual Stock Trading Pauses
September 29, 2010.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on
September 22, 2010, NASDAQ OMX
PHLX LLC (‘‘PHLX’’ or the ‘‘Exchange’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
PHLX Rule 3100(a)(4) to add securities
included in the Russell 1000 Index
(‘‘Russell 1000’’) and specified Exchange
Traded Products (‘‘ETP’’) to the
definition of Circuit Breaker Securities.
The text of the proposed rule change is
available from the Exchange’s Web site
at https://
nasdaqomxphlx.cchwallstreet.com, at
the Exchange’s principal office, and at
the Commission’s Public Reference
Room.
47 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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Agencies
[Federal Register Volume 75, Number 192 (Tuesday, October 5, 2010)]
[Notices]
[Pages 61541-61547]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-24899]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-63010; File No. SR-NASD-2003-140]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Notice of Filing of Amendment No. 4 and Order Granting
Accelerated Approval of a Proposed Rule Change, as Modified by
Amendment Nos. 1 Through 4, Relating to the Prohibition of Certain
Abuses in the Allocation and Distribution of Shares in Initial Public
Offerings (``IPOs'')
September 29, 2010.
I. Introduction
On September 15, 2003, the National Association of Securities
Dealers, Inc. (``NASD'') (n/k/a the Financial Industry Regulatory
Authority, Inc. (``FINRA'')) filed with the Securities and Exchange
Commission (``SEC'' or ``Commission''), pursuant to Section 19(b)(1) of
the Securities Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to adopt new FINRA Rule 5131
(originally proposed as NASD Rule 2712) to further and more
specifically prohibit certain abuses in the allocation and distribution
of shares in initial public offerings (``IPOs''). NASD amended the
proposed rule change on December 9, 2003 and August 4, 2004. On
February 10, 2010, FINRA filed with the Commission Amendment No. 3 to
SR-NASD-2003-140.\3\ The Commission published the proposed rule change,
as modified by Amendment No. 3, for comment in the Federal Register on
March 18, 2010.\4\ The Commission received three comment letters in
response to the proposed rule change.\5\ On July 30, 2010, FINRA
responded to the comment letters and filed Amendment No. 4 to the
proposed rule change. The Commission is publishing this notice and
order to solicit comments on Amendment No. 4, and to approve the
proposed rule change, as modified by Amendment Nos. 1 through 4, on an
accelerated basis.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 50896 (Dec. 20,
2004), 69 FR 77804 (Dec. 28, 2004).
\4\ See Securities Exchange Act Release No. 61690 (March 11,
2010), 75 FR 13176 (March 18, 2010) (``Amendment No. 3'').
\5\ See Letter from Jeffrey W. Rubin, Chair, Committee on
Federal Regulation of Securities, Business Law Section, American Bar
Association (``ABA''), to Elizabeth M. Murphy, Secretary, SEC, dated
April 6, 2010; Letter from Sean Davy, Managing Director, Corporate
Credit Markets Division, Securities Industry Financial Markets
Association (``SIFMA''), to Elizabeth M. Murphy, Secretary, SEC,
dated April 8, 2010; and Letter from Ross M. Langill, Chairman &
CEO, Regal Bay Investment Group LLC (``Regal''), to Elizabeth M.
Murphy, Secretary, SEC, dated April 8, 2010.
---------------------------------------------------------------------------
II. Description of Proposal
a. Quid Pro Quo Allocations
Proposed FINRA Rule 5131(a) would prohibit any member or person
associated with a member from offering or threatening to withhold
shares it allocates of a new issue as consideration or inducement for
the receipt of compensation that is excessive in relation to the
services provided by the member.
b. Prohibition on Spinning
Proposed FINRA Rule 5131(b) would prohibit the allocation of new
issue shares to the account of an executive officer or director of a
company (1) if the company is currently an investment banking services
client of the member or the member has received compensation from the
company for investment banking services in the past 12 months; (2) if
the member intends to provide, or expects to be retained by the company
for, investment banking services within the next 3 months; or (3) on
the express or implied condition that such executive officer or
director, on behalf of the company, will retain the member for the
performance of future investment banking services.
FINRA also proposes that members establish, maintain and enforce
policies and procedures reasonably designed to ensure that investment
banking personnel have no involvement or influence, directly or
indirectly, in the new issue allocation decisions of the member. The
spinning provision would apply to any account in which an executive
officer or director of a public company or a ``covered non-public
company,'' or a person materially supported by such executive officer
or director, has a beneficial interest. The term ``covered non-public
company'' would mean any non-public company satisfying the following
criteria: (i) Income of at least $1 million in the last fiscal year or
in two of the last three fiscal years and shareholders' equity of at
least $15 million; (ii) shareholders' equity of at least $30 million
and a two-year operating history; or (iii) total assets and total
revenue of at least $75 million in the latest fiscal year or in two of
the last three fiscal years.\6\ FINRA also proposes to prohibit new
issue allocations only where the person responsible for making the
allocation decision ``knows or has reason to know that the member
intends to provide, or expects to be retained by the company for,
investment banking services within the next 3 months.''
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\6\ These criteria are based on quantitative initial listing
standards for a national securities exchange, which FINRA believes
is a suitable proxy for the types of companies that are likely to be
targeted by members for investment banking services. In this case,
FINRA has determined that the applicable standards should be no less
than those required for initial listing on the NASDAQ Global Market.
FINRA further believes that, in modifying the scope of companies
covered by the spinning provisions, it is unnecessary to create a de
minimis standard for investment banking services compensation as
urged by ABA. Moreover, FINRA also believes that a de minimis
standard would pose additional compliance burdens and would be
susceptible to abuse by those seeking to avoid application of the
proposed rule.
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In addition, to facilitate compliance with the spinning provisions
as requested by commenters, proposed new Supplementary Material .02
would expressly permit members to rely on written representations
obtained within
[[Page 61542]]
the prior 12 months from the beneficial owner(s) of the account (or a
person authorized to represent the beneficial owner(s)) as to whether
such beneficial owner(s) is an executive officer or director (or person
materially supported by an executive officer or director) and if so,
the company(ies) on whose behalf such executive officer or director
serves. FINRA requires that the initial representation be an
affirmative representation, but will permit such representation to be
updated annually through the use of negative consent letters. Finally,
a member would be required to maintain a copy of all records and
information relating to whether an account is eligible to receive an
allocation of the new issue for at least three years following the
member's allocation to that account.
FINRA also proposes to include a limitation in the spinning rule
providing that the spinning prohibitions would not apply to allocations
made to any account described in FINRA Rule 5130(c)(1) through (3) and
(5) through (10), or to any other account in which the beneficial
interests of executive officers and directors of the company and
persons materially supported by such executive officers and directors
in the aggregate do not exceed 25% of such account.\7\ FINRA also
proposes to add a new definition of ``beneficial interest,'' which
would have the same meaning as FINRA Rule 5130.\8\
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\7\ One commenter asked that hedge funds clearly be included in
the proposal. See Regal. FINRA notes that hedge funds would be
included where the beneficial interest of executive officers and
directors of a particular company (and materially supported persons)
in the aggregate exceed 25%. FINRA continues to believe that the 25%
threshold is most appropriate and therefore will not increase the
standard to 50% as requested by one commenter. See ABA.
\8\ FINRA Rule 5130(i)(1) defines ``beneficial interest'' to
mean any economic interest, such as the right to share in gains or
losses. The receipt of a management or performance based fee for
operating a collective investment account, or other fees for acting
in a fiduciary capacity, shall not be considered a beneficial
interest in the account.
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FINRA proposes to use the term ``new issue'' throughout the
proposed rule and to use the same definition provided in FINRA Rule
5130(i)(9). Thus, the proposed rule, as amended, would apply to ``new
issues,'' meaning ``any initial public offering of an equity security
as defined in Section 3(a)(11) of the Act, made pursuant to a
registration statement or offering circular.'' As such, the proposed
definition of ``new issue'' would exclude:
Offerings made pursuant to an exemption under Section
4(1), 4(2) or 4(6) of the Securities Act of 1933 (``Securities Act''),
or Securities Act Rule 504 if the securities are ``restricted
securities'' under Securities Act Rule 144(a)(3), or Rule 144A or Rule
505 or Rule 506 adopted thereunder;
Offerings of exempted securities as defined in Section
3(a)(12) of the Act, and rules promulgated thereunder;
Offerings of securities of a commodity pool operated by a
commodity pool operator as defined under Section 1a(5) of the Commodity
Exchange Act;
Rights offerings, exchange offers, or offerings made
pursuant to a merger or acquisition;
Offerings of investment grade asset-backed securities;
Offerings of convertible securities;
Offerings of preferred securities;
Offerings of an investment company registered under the
Investment Company Act of 1940 (``Investment Company Act'');
Offerings of securities (in ordinary share form or ADRs
registered on Form F-6) that have a pre-existing market outside of the
United States; and
Offerings of a business development company as defined in
Section 2(a)(48) of the Investment Company Act, a direct participation
program as defined in Rule 2310(a) or a real estate investment trust as
defined in Section 856 of the Internal Revenue Code.
c. Policies Concerning Flipping
Proposed FINRA Rule 5131(c)(1) would prohibit members or persons
associated with a member from directly or indirectly recouping, or
attempting to recoup, any portion of a commission or credit paid or
awarded to an associated person for selling shares of a new issue that
are subsequently flipped by a customer, unless the managing underwriter
has assessed a penalty bid on the entire syndicate. Moreover, proposed
FINRA Rule 5131(c)(2) would require, in addition to any obligation to
maintain records relating to penalty bids under SEA Rule 17a-2(c)(1),
that members promptly record and maintain information regarding any
penalties or disincentives assessed on its associated persons in
connection with a penalty bid.
d. IPO Pricing and Trading Practices
(1) Indications of Interest
Proposed FINRA Rule 5131(d)(1) would require, in a new issue, the
book-running lead manager to provide to the issuer's pricing committee
(or, if the issuer has no pricing committee, its board of directors):
(1) A regular report of indications of interest, including the names of
interested institutional investors and the number of shares indicated
by each, as reflected in the book-running lead manager's book of
potential institutional orders, and a report of aggregate demand from
retail investors; and (2) after the settlement date of the new issue, a
report of the final allocation of shares to institutional investors as
reflected in the books and records of the book-running lead manager
including the names of purchasers and the number of shares purchased by
each, and aggregate sales to retail investors.
(2) Lock-Up Agreements
Proposed FINRA Rule 5131(d)(2) would require that any lock-up
agreement or other restriction on the transfer of the issuer's shares
by officers and directors of the issuer entered into in connection with
a new issue must provide that such restrictions will apply to their
issuer-directed shares. It also must provide that, at least two
business days before the release or waiver of any lock-up or other
restriction on the transfer of the issuer's shares, the book-running
lead manager will notify the issuer of the impending release or waiver
and announce the impending release or waiver through a major news
service. The exceptions to this notification requirement are where the
release or waiver is effected solely to permit a transfer of securities
that is not for consideration and where the transferee has agreed in
writing to be bound by the same lock-up agreement terms in place for
the transferor.
FINRA also is proposing new Supplementary Material .03 to provide
that the required announcement also may be made by another member or
the issuer (although it remains the responsibility of the book-running
lead manager to ensure that the impending release or waiver is properly
announced in compliance with this Rule).
(3) Returned Shares
Proposed FINRA Rule 5131(d)(3) would require that the agreement
between the book-running lead manager and other syndicate members must
require, to the extent not inconsistent with SEC Regulation M, that any
shares trading at a premium to the public offering price that are
returned by a purchaser to a syndicate member after secondary market
trading commences be used to offset the existing syndicate short
position. If no syndicate short position exists, proposed FINRA Rule
5131(d)(3)(B) would require the member to either: (1) Offer returned
shares at the public offering price to unfilled customers' orders
pursuant to a random allocation methodology; or (2) sell returned
shares on the secondary market and donate profits from the sale to an
[[Page 61543]]
``unaffiliated charitable organization'' with the condition that the
donation be treated as an anonymous donation to avoid any reputational
benefit to the member. Proposed FINRA Rule 5131 would establish a new
definition of ``unaffiliated charitable organization'' to prevent such
charitable donations from benefiting the member or executive officers
and directors of the member (and persons they materially support).\9\
The definition of ``unaffiliated charitable organization'' is closely
tied to specific information charities are required to file with the
Internal Revenue Service.
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\9\ Proposed FINRA Rule 5131(e)(9) defines ``unaffiliated
charatable organization'' as a tax-exempt entity organized under
Section 501(c)(3) of the Internal Revenue Code that is not
affiliated with the member and for which no executive officer or
director of the member, or person materially supported by such
executive officer or director, is an individual listed or required
to be listed on Part VII of the Internal Revenue Service Form 990
(i.e., officers, directors, trustees, key employees, highest
compensated employees and certain independent contractors).
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(4) Market Orders
Proposed FINRA Rule 5131(d)(4) would require that no member may
accept a market order for the purchase of shares of a new issue in the
secondary market prior to the commencement of trading of such shares in
the secondary market.
e. Definitions
Proposed FINRA Rule 5131(d) would provide the following
definitions. The term ``public company'' would mean any company that is
registered under Section 12 of the Exchange Act or files periodic
reports pursuant to Section 15(d) thereof. The term ``beneficial
interest'' would have the same meaning as defined in FINRA Rule
5130(i)(1). The term ``covered security'' would mean any non-public
company satisfying the following criteria: (i) Income of at least $1
million in the last fiscal year or in two of the last three fiscal
years and shareholders' equity of at least $15 million; (ii)
shareholders' equity of at least $30 million and a two-year operating
history; or (iii) total assets and total revenue of at least $75
million in the latest fiscal year or in two of the last three fiscal
years. The term ``flipped'' would mean the initial sale of new issue
shares purchased in an offering within 30 days following the offering
date of such offering.
In addition, proposed FINRA Rule 5131(d) would define the term
``investment banking services'' to include, without limitation, acting
as an underwriter, participating in a selling group in an offering for
an issuer or otherwise acting in furtherance of a public offering of
the issuer; acting as a financial adviser in a merger, acquisition or
other corporate reorganization; providing venture capital, equity lines
of credit, private investment, public equity transactions (PIPEs) or
similar investments or otherwise acting in furtherance of a private
offering of the issuer; or serving as placement agent for the issuer.
Under the proposed rule, the term ``material support'' would mean
directly or indirectly providing more than 25% of a person's income in
the prior calendar year. Persons living in the same household are
deemed to be providing each other with material support. The term ``new
issue'' would have the same meaning as in Rule 5130(i)(9). In addition,
the term ``penalty bid'' would mean an arrangement that permits the
managing underwriter to reclaim a selling concession from a syndicate
member in connection with an offering when the securities originally
sold by the syndicate member are purchased in syndicate covering
transactions. The term ``unaffiliated charitable organization'' would
mean a tax-exempt entity organized under Section 501(c)(3) of the
Internal Revenue Code that is not affiliated with the member and for
which no executive officer or director of the member, or person
materially supported by such executive officer or director, is an
individual listed or required to be listed on Part VII of the Internal
Revenue Service Form 990 (i.e., officers, directors, trustees, key
employees, highest compensated employees and certain independent
contractors).
Supplementary Material
Proposed FINRA Rule 5131 would also include supplementary material
regarding issuer directed allocations, in paragraph .01, which would
provide that the prohibitions of paragraph (b) of the rule would not
apply to securities that are directed in writing by the issuer, its
affiliates, or selling shareholders, so long as the member has no
involvement or influence, directly or indirectly, in the allocation
decisions of the issuer, its affiliates, or selling shareholders with
respect to such issuer-directed shares. Proposed FINRA Rule 5131 would
also provide supplementary material regarding annual representation, in
paragraph .02, which would provide that for purposes of paragraph (b)
of the rule, a member may rely on a written representation obtained
within the prior 12 months within the parameters set forth in paragraph
.02. The proposed rule would also provide supplementary material
regarding lock-up announcements, in paragraph .03, stating that the
requirement that the book-running lead manager announce the impending
release or waiver of a lock-up or other restriction on the transfer of
the issuer's shares shall be deemed satisfied where such announcement
is made by the book-running manager, another member or the issuer, so
long as such announcement otherwise complies with the requirements of
paragraph (d)(2) of Rule 5131.
The text of the proposed rule change is available on FINRA's Web
site at https://www.finra.org, at the principal office of FINRA, and at
the Commission's Public Reference Room.
III. Summary of Comments and Amendment No. 4
Prohibition on Spinning
Proposed FINRA Rule 5131(b) would prohibit the allocation of IPO
shares to the account of an executive officer or director of a company
(1) if the company is currently an investment banking services client
of the member or the member has received compensation from the company
for investment banking services in the past 12 months; (2) if the
member intends to provide, or expects to be retained by the company
for, investment banking services within the next 3 months; or (3) on
the express or implied condition that such executive officer or
director, on behalf of the company, will retain the member for the
performance of future investment banking services.
Commenters generally supported the proposed changes to the spinning
rule but requested additional modifications.\10\ Commenters' concerns
included that it would be difficult to identify the universe of
officers and directors subject to the rule and asked that members be
permitted to rely on annual negative consent letters.\11\ One commenter
expressed particular concern regarding the applicability of the rule to
officers and directors of non-public companies.\12\
---------------------------------------------------------------------------
\10\ See SIFMA.
\11\ See ABA and SIFMA.
\12\ See SIFMA.
---------------------------------------------------------------------------
In response to commenters' concerns, FINRA is proposing several
changes to the spinning provisions. First, FINRA proposes that members
establish, maintain and enforce policies and procedures reasonably
designed to ensure that investment banking personnel have no
involvement or influence, directly or indirectly, in the new issue
allocation decisions of the member. FINRA believes that such procedures
are essential to managing conflicts of interest between investment
[[Page 61544]]
banking and syndicate activities. FINRA understands that these
procedures are customary at members today, and wants to ensure that
such policies and procedures remain in force.
In addition, in response to comments, FINRA proposes to narrow the
scope of the non-public companies covered by the spinning provision to
focus the rule and firms' compliance efforts on those allocations that
have the greatest potential for abuse. Specifically, the spinning
provision would apply to any account in which an executive officer or
director of a public company or a ``covered non-public company,'' or a
person materially supported by such executive officer or director, has
a beneficial interest. The term ``covered non-public company'' means
any non-public company satisfying the following criteria: (i) Income of
at least $1 million in the last fiscal year or in two of the last three
fiscal years and shareholders' equity of at least $15 million; (ii)
shareholders' equity of at least $30 million and a two-year operating
history; or (iii) total assets and total revenue of at least $75
million in the latest fiscal year or in two of the last three fiscal
years.\13\
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\13\ These criteria are based on quantitative initial listing
standards for a national securities exchange, which FINRA believes
is a suitable proxy for the types of companies that are likely to be
targeted by members for investment banking services. In this case,
FINRA has determined that the applicable standards should be no less
than those required for initial listing on the NASDAQ Global Market.
FINRA further believes that, in modifying the scope of companies
covered by the spinning provisions, it is unnecessary to create a de
minimis standard for investment banking services compensation as
urged by ABA. Moreover, FINRA believe that a de minimis standard
would pose additional compliance burdens and would be susceptible to
abuse by those seeking to avoid application of the proposed rule.
---------------------------------------------------------------------------
One commenter stated that it may be difficult to determine when the
member ``intends to provide'' investment banking services and asked
that the member be permitted to rely on policies and procedures
reasonably designed to determine whether an entity is a current or
prospective investment banking client, or whether the member intends to
provide investment banking services to a prospective client, on the
basis of reasonable criteria (which criteria may limit the
identification of current clients to those relationships that are more
than aspirational or passing, or for which the firm has a reasonable
expectation of an active near-term relationship).\14\ FINRA does not
believe that the spinning provision should be recast solely as a
``policies and procedures'' rule. However, in response to commenters'
concerns and in light of the provision explicitly requiring policies
and procedures excluding investment banking personnel input into new
issue allocation decisions, FINRA proposes to modify the three month
forward looking provision to prohibit new issue allocations only where
the person responsible for making the allocation decision ``knows or
has reason to know that the member intends to provide, or expects to be
retained by the company for, investment banking services within the
next 3 months.'' FINRA believes that this change strikes an appropriate
balance in addressing the potential that new issue allocations will
influence future business with the member while not unnecessarily
impacting the capital formation process.\15\ However, according to
FINRA, if a member maintains effective information barriers between the
investment banking and syndicate departments and the persons
responsible for making new issue allocation decisions neither know nor
have reason to know of the prospective business relationship, the
forward-looking provision will not be violated.
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\14\ See SIFMA.
\15\ If an executive officer or director receives an allocation
and the investment bank subsequently is retained for the performance
of investment banking services within the three month window by such
executive officer or director's employing firm, FINRA will
investigate the particular information about the business
relationship that was known (and by whom) at the time of the
allocation, including a review of the communications between the
broker-dealer and the investment banking client, and between the
investment banking and syndicate departments, as well as the
member's systems for logging and managing prospective and current
client and transaction information.
---------------------------------------------------------------------------
To facilitate compliance with the spinning provisions as requested
by commenters, proposed new Supplementary Material .02 expressly
permits members to rely on written representations obtained within the
prior 12 months from the beneficial owner(s) of the account (or a
person authorized to represent the beneficial owner(s)) as to whether
such beneficial owner(s) is an executive officer or director (or person
materially supported by an executive officer or director) and if so,
the company(ies) on whose behalf such executive officer or director
serves. Consistent with current practice under FINRA Rule 5130, FINRA
requires that the initial representation be an affirmative
representation, but will permit such representation to be updated
annually through the use of negative consent letters. Members are
reminded that a member may not rely upon any representation it
believes, or has reason to believe, is inaccurate. Finally, a member
would be required to maintain a copy of all records and information
relating to whether an account is eligible to receive an allocation of
the new issue for at least three years following the member's
allocation to that account.
FINRA notes that members should understand that the representation
in the spinning context differs from that in FINRA Rule 5130 because,
in the spinning case, the information obtained from the customer is
not, by itself, sufficient to make a determination of whether a
customer is eligible to purchase a new issue. Members also must
determine whether each account considered for a new issue allocation
involves an executive officer or director (or materially supported
person) of a current or prospective client that falls within the scope
of paragraph (b). Members may choose to adopt a more restrictive
internal policy prohibiting allocations to all executive officers,
directors and materially supported persons; however, FINRA notes that
this is not required under the proposed rule change.\16\
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\16\ FINRA notes that the Voluntary Initiative more broadly
prohibited allocations to the account of any executive officer or
director of a U.S. public company or a public company for which a
U.S. market is the principal equity trading market with respect to
all hot IPOs. Voluntary Initiative Regarding Allocations of
Securities in ``Hot'' Initial Public Offerings to Corporate
Executives and Directors, https://www.sec.gov/news/press/globalvolinit.htm (Apr. 28, 2003).
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Commenters also asked that the definition of ``account of an
executive officer or director'' be amended to apply to accounts in
which an executive officer, director or materially supported person has
a ``beneficial interest'' rather than a ``financial interest.'' \17\
Commenters asked that the rule exclude accounts over which executive
officers, directors or materially supported persons have ``discretion
or control'' as this may unduly impact allocations to certain
funds.\18\ Commenters further argued that the definition of ``account
of an executive officer or director'' should be modified to exclude
certain other entities (such as foreign investment companies)
consistent with FINRA Rule 5130(c).\19\
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\17\ See ABA. Commenters generally favored the use of defined
terms in proposed FINRA Rule 5131 that are consistent with the terms
used in Rule 5130. See ABA and Regal.
\18\ See ABA.
\19\ See ABA.
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In response to comments, FINRA proposes to delete the definition of
``account of an executive officer or director'' and to instead include
a new limitation in the spinning rule providing that the spinning
prohibitions would not apply to allocations made to any account
described in FINRA Rule 5130(c)(1) through (3) and (5) through
[[Page 61545]]
(10), or to any other account in which the beneficial interests of
executive officers and directors of the company and persons materially
supported by such executive officers and directors in the aggregate do
not exceed 25% of such account.\20\ As requested by commenters, FINRA
also proposes to add a new definition of ``beneficial interest,'' which
will have the same meaning as FINRA Rule 5130.\21\ FINRA believes
deleting the term ``account of an executive officer or director'' and
modifying the scope of the rule to generally exclude those accounts
excepted from FINRA Rule 5130(c) is appropriate in that allocations to
such accounts are not likely to result in the type of abuse the
spinning prohibition is geared toward. FINRA believes that the
proposal, as amended, continues to meet the goals of the rule while
avoiding an unnecessary impact on capital formation. In addition, by
replacing references to ``financial interest'' with ``beneficial
interest'' and deleting the reference to accounts in which officers and
directors exercise ``discretion or control,'' FINRA believes that the
rule more properly focuses on accounts in which relevant parties have
an economic interest.
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\20\ One commenter asked that hedge funds clearly be included in
the proposal. See Regal. FINRA notes that hedge funds would be
included where the beneficial interest of executive officers and
directors of a particular company (and materially supported persons)
in the aggregate exceed 25%. FINRA continues to believe that the 25%
threshold is most appropriate and therefore will not increase the
standard to 50% as requested by one commenter. See ABA.
\21\ FINRA Rule 5130(i)(1) defines ``beneficial interest'' to
mean any economic interest, such as the right to share in gains or
losses. FINRA notes that the receipt of a management or performance
based fee for operating a collective investment account, or other
fees for acting in a fiduciary capacity, shall not be considered a
beneficial interest in the account.
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Commenters argued that the spinning rule should apply only to ``hot
IPOs'' and should exclude the types of offerings excepted under FINRA
Rule 5130(i)(9).\22\ FINRA does not agree that the rule should apply
only to ``hot IPOs.'' FINRA believes that the proposed rule change
should not be limited to hot IPOs for the same reasons that FINRA Rule
5130 is not limited to hot IPOs.\23\ Specifically, the operation of a
rule based on an unknown future event--the opening price--creates
compliance difficulties and potentially may exacerbate spinning
problems and may harm capital formation by necessitating members to
cancel allocations and reallocate shares to another customer. FINRA
does, however, agree that certain types of offerings that are not
likely to trade at a premium in the aftermarket should be excluded from
the rule. Therefore, FINRA proposes to replace the defined term
``initial public offering'' or ``IPO'' with the term ``new issue''
throughout the proposed rule and to use the same definition provided in
FINRA Rule 5130(i)(9). In developing the definition of ``new issue'' in
FINRA Rule 5130, FINRA carefully considered the extent to which such
offerings may be hot issues. Thus, the proposed rule, as amended,
applies to ``new issues,'' meaning ``any initial public offering of an
equity security as defined in Section 3(a)(11) of the Act, made
pursuant to a registration statement or offering circular.''
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\22\ See ABA.
\23\ While earlier proposed versions of the IPO Rule would have
applied only to ``hot issues,'' FINRA, then NASD, revised the
proposal to cover the purchase and sale of all initial equity public
offerings, not just those that open above a designated premium,
because FINRA believed the revised approach would be easier to
understand and would avoid many of the complexities associated with
the cancellation provision. See Securities Exchange Act Release No.
48701 (October 24, 2003), 68 FR 62126 (October 31, 2003) (Order
Approving File No. SR-NASD-99-60). (Proposed rule change relating to
restrictions on the purchases and sales of initial public offerings
of equity securities).
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IPO Pricing and Trading Practices
Commenters generally supported the amended proposal related to IPO
Pricing and Trading Practices.\24\ However, one commenter asked that
FINRA include clarifying language that the lock-up provision would only
apply to lock-ups entered into in connection with the IPO, and not with
respect to other lock-up agreements.\25\ FINRA confirms that this
provision applies only to lock-up agreements entered into in connection
with a new issue and has modified the rule text to reflect this.\26\
This commenter also asked that FINRA clarify that the required notice
of an impending release or waiver of a lock-up may be announced either
by the issuer or the applicable member(s).\27\ FINRA agrees that, so
long as the announcement is made through a major news service at least
two days before the release or waiver of any lock-up or other
restriction on the transfer of the issuer's shares, the requirement is
satisfied irrespective of whether such announcement is made by the
book-running lead manager, another member or by the issuer. Thus, FINRA
is proposing new Supplementary Material .03 in response to comments to
provide that the required announcement also may be made by another
member or the issuer. However, FINRA notes that it remains the
responsibility of the book-running lead manager to ensure that the
impending release or waiver is properly announced in compliance with
this Rule.
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\24\ See SIFMA.
\25\ See SIFMA.
\26\ Proposed Rule 5131(d)(2), as amended, provides that ``[a]ny
lock-up agreement or other restriction on the transfer of the
issuer's shares by officers and directors of the issuer entered into
in connection with a new issue shall provide that * * *'' (new
language emphasized).
\27\ See SIFMA.
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One commenter argued that the rule should be changed to permit the
syndicate to retain discretion to either use returned shares to reduce
the syndicate position or toward unfilled customer orders.\28\ FINRA
does not agree that this change is appropriate. FINRA expects that when
shares trade at a premium to the public offering price, the incidence
of returned shares should be minimal so as not to affect the ability of
syndicate members to stabilize the market for such shares to the extent
stabilization activities are even necessary. Further, FINRA believes
that the complexity of addressing this alternative would unnecessarily
complicate the proposed rule change.\29\ However, in response to
comments, FINRA is amending the rule to provide members with additional
flexibility in the handling of returned shares. The amended proposal
continues to require that, to the extent not inconsistent with SEC
Regulation M, the agreement between the book-running lead manager and
other syndicate members must require that any shares trading at a
premium to the public offering price returned by a purchaser to a
syndicate member after secondary market trading commences be used to
offset the existing syndicate short position.\30\ However, where no
syndicate short position exists, the proposed rule
[[Page 61546]]
change would provide the member with the option, provided that it is in
accordance with SEC Regulation M, to either: (1) Offer returned shares
at the public offering price to unfilled customers' orders pursuant to
a random allocation methodology or (2) sell returned shares on the
secondary market and donate profits from the sale to an ``unaffiliated
charitable organization'' with the condition that the donation be
treated as an anonymous donation to avoid any reputational benefit to
the member.\31\ Proposed FINRA Rule 5131 establishes a new definition
of ``unaffiliated charitable organization'' to prevent such charitable
donations from benefiting the member or executive officers and
directors of the member (and persons they materially support). FINRA
believes that charitable donations funded by returned shares should not
provide any reputational benefit to the member. The definition of
``unaffiliated charitable organization'' is closely tied to specific
information charities are required to file with the Internal Revenue
Service.
---------------------------------------------------------------------------
\28\ See SIFMA.
\29\ SIFMA also asked FINRA to clarify that anonymous, ordinary
course sales on a national securities exchange or ATS at market
prices will be considered a ``random allocation'' for the purposes
of the rule. FINRA disagrees. The provision, as previously proposed
would have required that, where no syndicate short position exists,
the member must offer the returned shares to unfilled customer
orders at the public offering price, not the market price. Moreover,
FINRA notes that, if the shares are trading at a premium to the
public offering price, then sales by the member at market prices
would result in the premium inuring to the benefit of the member,
which is inconsistent with the purpose of the provision and a
member's obligations under FINRA Rule 5130.
\30\ One commenter asked for confirmation that the appropriate
time for determining whether returned shares are trading at a
premium to their IPO price is at the time such securities are
returned. FINRA agrees. See SIFMA. Another commenter argued that the
requirement that members use a random allocation methodology to
reallocate returned shares was inadequate. See Regal. FINRA
disagrees and notes that this standard is already used successfully
in other FINRA rules. See FINRA Rule 2360 (Allocation of Exercise
Assignment Notices).
\31\ Proposed FINRA Rule 5131(e)(9) defines ``unaffiliated
charitable organization'' as a tax-exempt entity organized under
Section 501(c)(3) of the Internal Revenue Code that is not
affiliated with the member and for which no executive officer or
director of the member, or person materially supported by such
executive officer or director, is an individual listed or required
to be listed on Part VII of Internal Revenue Service Form 990 (i.e.,
officers, directors, trustees, key employees, highest compensated
employees and certain independent contractors).
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The proposed rule change, as amended, prohibits the acceptance of
market orders for the purchase of IPO shares prior to the commencement
of trading on the secondary market. A commenter supported the proposed
amendment but offered alternative rule text.\32\ FINRA favors its
existing rule text but proposes a slight modification in response to
comments to further clarify the provision such that the relevant text
will now state that ``no member may accept a market order for the
purchase of shares of a new issue in the secondary market prior to the
commencement of trading of such shares in the secondary market.''
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\32\ See SIFMA.
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Other Issues
Commenters reiterated certain concerns regarding FINRA's proposed
provision relating to abusive allocation arrangements. Proposed FINRA
Rule 5131(a) prohibits a member from offering or threatening to
withhold shares it allocates in an IPO as consideration or inducement
for the receipt of compensation that is excessive in relation to the
services provided by the member (i.e., quid pro quo allocations).
Commenters generally supported this proposed provision but reiterated
earlier concerns that the term ``excessive'' is subject to
uncertainty.\33\ One commenter requested that FINRA clarify that any
services provided for a ``fair price'' as provided by FINRA's Corporate
Financing Rule (Rule 5110(a)(9)) would not be deemed excessive.\34\
This commenter also requested guidance that any services provided by a
member paid for using ``soft dollars'' in conformity with Section 28(e)
of the Act also would not be deemed excessive.\35\ Another commenter
asked that clarifying language be added to the rule to provide that an
assessment of whether compensation is excessive would be based on the
relevant facts and circumstances including, where applicable, the level
of risk and effort involved in the transaction and the rates generally
charged for such services.\36\
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\33\ See ABA and SIFMA.
\34\ See ABA.
\35\ See ABA.
\36\ See SIFMA.
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As stated in Amendment No. 3, FINRA agrees that an assessment of
whether or not compensation is excessive would be based upon all of the
relevant facts and circumstances including, where applicable, the level
of risk and effort involved in the transaction and the rates generally
charged for such services.\37\ However, FINRA continues to believe that
the proposed language, which refers to ``compensation that is excessive
in relation to the services provided,'' is most appropriate in that it
affords FINRA the necessary flexibility in addressing the range of
potential quid pro quo arrangements that may arise. As stated in
Amendment No. 3, FINRA does not believe it is necessary to include rule
text stating that an assessment of whether compensation is
``excessive'' will be based upon all of the relevant facts and
circumstances.\38\ Likewise, FINRA does not believe it is appropriate
to provide blanket guidance regarding payments made in conformity with
Section 28(e) of the Act or FINRA Rule 5110(a)(9).
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\37\ See Amendment No. 3.
\38\ See Amendment No. 3.
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Finally, one commenter raised concerns regarding FINRA's proposed
flipping provision.\39\ This commenter argued that, instead of defining
the flipping period to mean the initial sale of new issue shares within
30 days following the offering date, the flipping provision should be
based on the sale of shares prior to the book manager lifting the
penalty bid, making the time period under the rule subject to the
discretion of the managing underwriter.\40\ FINRA does not agree that
the suggested alternative represents an improvement to the proposed
provision. FINRA believes that the certainty and finality of the
proposed approach, including the 30-day window, is the appropriate
duration for prohibiting members from recouping commissions from
associated persons whose customers sell in cases where a penalty bid
has not been assessed on the entire syndicate.
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\39\ See Regal.
\40\ See Regal.
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FINRA will announce the effective date of the proposed rule change
in a Regulatory Notice to be published no later than 60 days following
Commission approval. The effective date will be no less than 90 and no
more than 180 days following publication of the Regulatory Notice
announcing Commission approval.
IV. Discussion and Commission Findings
After carefully considering the proposal, the comments submitted,
and FINRA's response to the comments, the Commission finds that the
proposed rule change, as modified by Amendment Nos. 1 through 4, is
consistent with the requirements of the Act and the rules and
regulations thereunder applicable to a national securities
association.\41\ In particular, the Commission finds that the proposed
rule change, as amended, is consistent with Section 15A(b)(6) of the
Act,\42\ which requires, among other things, that FINRA rules be
designed to prevent fraudulent and manipulative acts and practices, to
promote just and equitable principles of trade, and, in general, to
protect investors and the public interest. In particular, the
Commission believes that the proposed rule change is a reasonable step
to enhance members' avoidance of unacceptable conduct when they engage
in the allocation and distribution of new issue shares. The Commission
also believes that the proposed rule change is a reasonable step to
enhance public confidence in the distribution of new issues.
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\41\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
\42\ 15 U.S.C. 78o-3(b)(6).
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In addition, the Commission sought specific comment in Amendment
No. 3 on whether there are any alternatives to the proposed rule change
that FINRA should consider, such as whether proposed Rule 5131(b)'s
spinning provisions should be modified to
[[Page 61547]]
include a mandatory ban prohibiting members from seeking or providing
investment banking services to a company for a period of 12 months
following any allocation of IPO shares to an account of an executive
officer or director of such company and whether such a ban would
facilitate compliance. One commenter strongly supported a 12-month
prohibition.\43\ However, another commenter opposed such a prohibition,
saying that it ``would--by rule--impose an automatic sanction for even
inadvertent allocations of IPO securities'' and ``would, in all cases,
be financially disproportionate to the value of the securities involved
in any violation, would not take into account the specific facts of
each situation, deprive the FINRA member of its statutory right to a
fair hearing before the imposition of any disciplinary sanction, and
would unfairly deprive the company of the right to select the services
of the FINRA member.'' \44\ According to this commenter, in each case,
the imposition of a mandatory ban, as suggested by the Commission,
would be an excessive penalty in light of the facts and circumstances
underlying the potential violation of the proposed rule.\45\
Nevertheless, this commenter noted that the 12-month prohibition
``should not in any event be approved without an opportunity for review
of and comment on the text of the proposed rule,'' with commenter
requesting that the Commission republish for comment any proposal to
adopt such a mandatory ban on investment banking services with a sixty-
day comment period. In light of these comments, the Commission will
continue to consider the commenters' recommendations and concerns in
considering whether any future action is warranted. However, the
Commission does not believe this issue should preclude approval of the
proposal.
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\43\ See Regal.
\44\ See ABA.
\45\ See id.
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V. Accelerated Approval
The Commission finds good cause, pursuant to Section 19(b)(2) of
the Act,\46\ for approving the proposed rule change, as modified by
Amendment Nos. 1 through 4 thereto, prior to the 30th day after the
date or publication of Amendment No. 4 in the Federal Register. The
changes proposed in Amendment No. 4 respond to specific concerns
raised. Moreover, accelerating approval of this proposal should benefit
FINRA members by aiding them in avoiding misconduct in new issue
distributions and should benefit investors by taking a step to enhance
investor protection in the capital raising process.
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\46\ 15 U.S.C. 78s(b)(2).
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VI. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change, as modified by Amendment No. 4, is consistent with the Act.
Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number SR-NASD-2003-140 on the subject line.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number SR-NASD-2003-140. This file
number should be included on the subject line if e-mail is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official business days between the hours of 10
a.m. and 3 p.m. Copies of such filing also will be available for
inspection and copying at the principal office of FINRA. All comments
received will be posted without change; the Commission does not edit
personal identifying information from submissions. You should submit
only information that you wish to make available publicly. All
submissions should refer to File Number SR-NASD-2003-140 and should be
submitted on or before October 26, 2010.
VII. Conclusion
It is therefore ordered pursuant to Section 19(b)(2) of the Act,
that the proposed rule change (SR-NASD-2003-140), as modified by
Amendment Nos. 1 through 4, be, and hereby is, approved on an
accelerated basis.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\47\
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\47\ 17 CFR 200.30-3(a)(12).
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Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010-24899 Filed 10-4-10; 8:45 am]
BILLING CODE 8010-01-P