FINRA Rule Amendments, Regulation S Compliance, ETN Splits
Summary
Mayer Brown's REVERSEinquiries Newsletter, Volume 7 Issue 2 covers FINRA enforcement (a member firm settled for inadequate Regulation S compliance procedures), a FINRA proposed rule change (Rule 2210 amendments to permit use of projections), a Second Circuit court ruling dismissing an ETN reverse stock split lawsuit, day-count conventions in structured products, and monitoring program issuance limits.
What changed
This newsletter itemises four discrete developments in structured and market-linked products. FINRA settled an enforcement matter with a member firm for failing to maintain appropriate procedures for Regulation S compliance. Separately, FINRA proposed amendments to Rule 2210 that would permit member communications to include projections. The Second Circuit affirmed dismissal of a suit involving an ETN reverse stock split. Day-count conventions and monitoring program issuance limits are also addressed.
Broker-dealers and structured-product market participants should note the Rule 2210 proposal as a prospective change to communications standards, the Regulation S enforcement as a reminder of procedural obligations, and the Second Circuit ruling as a judicial interpretation affecting ETN reverse-split litigation risk.
Archived snapshot
Apr 22, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 21, 2026
REVERSEinquiries Newsletter, Volume 7, Issue 2
Bradley Berman, Elizabeth Encinas, Marla Matusic, Anna Pinedo Mayer Brown + Follow Contact LinkedIn Facebook X ;) Embed Structured and Market-linked Product News for Inquiring Minds -
REVERSEinquiries is Mayer Brown’s structured and market-linked products-focused newsletter.
In this issue, we discuss:
Every Day Counts—Or Does It? Day Counts Revisited
FINRA Member Settles with FINRA for Failure to Maintain Appropriate Procedures for Regulation S Compliance
FINRA Proposes Amendments to Rule 2210 to Permit Use of Projections
Second Circuit Affirms Dismissal of Suit Involving ETN Reverse Stock Split
Staying on the Right Track: Monitoring Program Issuance Limits
Please see full publication below for more information.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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