In This Issue:

- The National Senior Investor Initiative

- SEC Commissioner Addresses Structured Notes

- The SEC Defines “Voting Equity Securities” Under the Rule 506(d) Bad Actor Disqualification Rules

- For Members Only: FINRA Updates Rules re: Payments to Non-Members

- Losing WKSI Status: Consequences for Structured Note Dealers

- Excerpt from The National Senior Investor Initiative:

On April 15, 2015, the SEC’s Office of Internal Compliance Inspections and Examinations (OCIE), together with FINRA, released a report focusing on sales of investment products to seniors, including investments in structured products.1 The report, as well as increased scrutiny by the SEC and FINRA on investments by the elderly in general, is a reflection of the aging American population and the need of many of them for higher-yielding investments. Further, traditional investments, such as savings accounts, are earning historically low yields, resulting in an increased interest in non-traditional securities.

The report is based on 44 examinations conducted in 2013, which focused on how firms conduct business with senior investors.