FINRA Reminds Securities Broker-Dealers of Their Duty of Due Diligence to Prevent the Public Resale of 'Unregistered Securities'

摘要

We believe that Regulatory Notice 09-05 of FINRA serves a very useful purpose by refocusing those of us who are control and securities law practitioners on the need for securities brokerage firms to have procedures in place, that will prevent the illegal sale of unregistered securities, and to have those procedures enforced. As noted above, it also refocuses us on the need for each publicly traded company to have in place an effective "pre-clearance" procedure, which will complement the procedure established at the securities brokerage firms.