Structured Thoughts -- Volume 4, Issue 4 -- February 28, 2013

Morrison & Foerster LLP
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In This Issue:

Additional SEC Guidance on Estimated Value Disclosures; 2013 OCIE Examination Priorities Have Implications for Structured Products Issuers and Dealers; EITF and the Federal Funds Rate; and FDIC Proposes to Nix Insurance for Dually Payable Deposits.

Excerpt from Additional SEC Guidance on Estimated Value Disclosures -

In February 2013, the Staff of the Division of Corporation Finance provided additional guidance to a number of issuers relating to their structured note disclosures.

Since the release of the SEC’s “sweep letter” in April 2012, market participants have been focused on revising their structured products offering documents to address the issues raised in the letter. The new guidance relates to the portions of the sweep letter that have generated the most discussion, that is, the new requested disclosures relating to the “estimated initial value” of structured notes and secondary market pricing practices.

Please see full publication below for more information.

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