On March 30th, FINRA published a Regulatory Notice reminding firms that, pursuant to new FINRA Rule 4110(e)(1), subordinated loans and notes collateralized by securities (together referred to as subordinations) must be approved by FINRA in order to receive beneficial regulatory capital treatment. The Notice explains the requirements for all subordinations for which firms intend to receive beneficial regulatory capital treatment, including certain provisions that all such subordinations, both standard and non-standard, must contain. It also describes the submission and approval process of proposed subordinations. FINRA Regulatory Notice.