On December 16, the Financial Industry Regulatory Authority (FINRA) issued guidance regarding member firm sales of investment products marketed as alternatives to cash holdings. Although all member firm communications must comply with applicable FINRA sales practices rules, the notice specifically cautions firms selling “cash alternative” products to: (i) avoid overstating a product’s similarities to a cash holding and provide balanced disclosure of the risks and returns associated with a particular product; (ii) conduct adequate due diligence to understand the features of a product; (iii) conduct appropriate customer suitability analyses; (iv) monitor market and economic conditions that may cause the description of an investment as a cash alternative to become inaccurate or misleading, and adopt procedures reasonably designed to ensure that the firm responds to those changing conditions; and (v) train registered persons regarding the features, risks and suitability of these products.