On June 4, 2012, the Financial Industry Regulatory Authority (“FINRA”) will introduce a new electronic filing system for public offerings that are required to be filed under FINRA Rules 5110, 5121 and 2310 (the “Corporate Financing Rules”). The new Public Offering System is intended to provide operational efficiencies and useful enhancements for filers. The new system will replace COBRADesk, which has been operational since 1999, and which will be retired on June 20, 2012. Any data included in COBRADesk will need to be retrieved before its retirement if an underwriter wishes to have access to it. In addition, offerings that were filed in COBRADesk and that are under review as of that date must be refiled in the new system.

This alert summarizes the changes that will occur, and sets forth FINRA’s transition timetable and key dates.