A reminder that the new equity research rules, contained in FINRA Rule 2241, became fully effective on December 24, 2015.  The equity research rules, among other things, revise the quiet periods applicable to member firms during which member firms may not publish or distribute equity research reports.  As a reminder, the new quiet periods (which were effective as of September) are now:

  • 10 days following an IPO for participating member firms;
  • 3 days following a follow-on offering for member firms that act as managers or co-managers; and
  • No quiet period in relation to the expiration, waiver or termination of a lock-up agreement entered into in connection with a public offering.

The quiet periods do not apply to research related to IPOs or follow-on offerings for EGCs.  Also, member firms may publish research concerning a company the securities of which are actively traded in compliance with the Rule 139 safe harbor.