In September 2014, FINRA proposed rule changes addressing when broker-dealers may pay referral fees or share their compensation with parties other than registered broker-dealers. Our firm’s client alert relating to the proposed rules may be found at the following link: http://www.mofo.com/~/media/Files/ClientAlert/2014/10/141016ReferralFees.pdf.

The proposed amendments are relevant to those sales of structured notes that involve a proposed referral fee or other compensation to a non-FINRA member. For example, a non-U.S. firm may seek compensation from a U.S. underwriter in connection with an account opening, or sales of particular instruments.