On September 17th, the SEC's National Examination Program issued a risk alert to highlight risks to firms from non-compliance with Rule 105 of Regulation M, which prohibits the short sale of an equity security during a restricted period - generally five business days before a public offering - and the purchase of that same security through the offering. The rule applies regardless of the trader's intent. The risk alert highlights observations by SEC examiners focusing on Rule 105 compliance issues as well as corrective actions that some firms proactively have taken to remedy Rule 105 concerns.