Effective March 1, 2010, FINRA inaugurated a same day clearance option for filers submitting accelerated base, takedown, and concurrent (simultaneous filing of a base and takedown) shelf offerings for offerings required to be filed under Rule 5110, the Corporate Financing Rule.1 The same day clearance option provides an immediate no objections opinion upon the successful filing of a shelf offering via COBRADesk, FINRA’s online filing system, although the transaction will be subject to post-offering review and verification. In order to take advantage of the same day clearance process (“SDC”), the filer must make a number of representations, by means of checking the appropriate boxes in the filing, depending on the nature of the offering. Our earlier SDC alert details the required representations.2

FINRA recently appended a frequently asked questions (“FAQs”) section to its COBRADesk Same Day Clearance Guide available on the COBRADesk website. Some of the more interesting answers to FAQs are....