In a recent rule filing, Financial Industry Regulatory Authority (FINRA) once again delayed the implementation date of its expansion of the “Manning” rule to over-the-counter (OTC) equity securities. OTC equity securities include any non-exchange-listed security (e.g., OTCBB, ADRs, pink sheets, etc.) and certain exchange-listed securities that do not otherwise qualify for real-time trade reporting. Currently, the Manning interpretation places restrictions on trading ahead of customer limit orders only with respect to exchange-listed securities. The new implementation date has now been set for January 14, 2008. The rule changes were previously scheduled to take effect first in July, 2007 and then in November, 2007, but were delayed to allow firms to make necessary systems changes.