Search

The article reports that the Ministry of Finance (MOF) has issued a Circular for guiding the foreign investment activities on the Vietnam securities market and discusses several caps in some financial business.

Purpose – The purpose of this paper is to examine the efficacy of recent policy initiatives taken by the US Securities and Exchange Commission banning naked "short-selling" of specific financial stocks. The paper also considers the merits of reinstating "uptick rule" 10a-1, which prohibits short-selling securities on a downtick. Design/methodology/approach – The paper studies theoretical implications of short-selling in a simple state-claim model, reflecting varying amounts of short interest in a representative firm and noise trading in the market. Price discovery depends on the proportion of noise trading compared to rational short-selling. The empirical analysis focuses on price volatility under short-selling constraints employing simple regressions, EGARCH analysis and simulated price behavior under a hypothetical uptick rule. Findings – The EGARCH results suggest short-selling constraints had non-uniform impacts on the persistence and leverage effects associated with price volatility. The corresponding price simulations indicate a hypothetical uptick rule might have helped stabilize price behavior in some cases, depending on the nature of the stochastic process and whether or not quantity constraints on short-selling are binding. Originality/value – The theoretical arguments and empirical findings suggest a "focused approach" to market regulation would be a more efficient means of discouraging trend chasing without compromising "informed trading" – that is to say, safeguarding price discovery and market liquidity without impeding arbitrage or confounding probability beliefs regarding firm survival. These conclusions are largely in accord with recent policy analysis and proposals outlined in Avgouleas. [ABSTRACT FROM AUTHOR]

Purpose -- The purpose of this summary is to provide excerpts of selected Financial Industry Regulatory Authority (FINRA) regulatory notices and disciplinary actions issued in July and August 2009 and a sample of disciplinary actions during that period. Design/methodology/approach -- The paper provides excerpts from FINRA Regulatory Notice 09-42, Variable Life Settlement Transactions; 09-49, Conflicts of Interest; 09-52, Trade Reporting; and 09-53, Non-traditional ETFs. Findings -- (09-42) FINRA is concerned about variable fife settlements because they involved materially different factors and raise materially different issues than more widely held securities such as stocks or bonds. (09-49) Rule 2720 prohibits a member firm with a conflict of interest from participating in a public offering, unless the nature of the conflict is prominently disclosed and certain other specific requirements are met. (09-52) Effective January 11, 20#0, firms that execute OTC trades in equity/ securities during the hours that a FINRA trade reporting facility is closed must report the trade within 15 minutes of the opening of the facility. (09-53) Effective December 1, 2009, FINRA is implementing increased customer margin requirements for leveraged ETFs and uncovered options overlaying leveraged ETFs. Originality/value -- These are direct excerpts designed to provide a useful digest for the reader and an indication of regulatory trends. The FINRA staff are aware of this summary but have neither reviewed, nor edited it. For further detail as well as other useful information, the reader should visit www.finra.org [ABSTRACT FROM AUTHOR]

Purpose -- The purpose of this summary is to provide excerpts of selected Financial Industry Regulatory Authority (FINRA) Regulatory Notices and Disciplinary Actions issued from April to June 2009 and a sample of disciplinary actions during that period. Design/methodology/approach -- The paper provides excerpts from Regulatory Notice 09-22, Personal Securities Transactions; 09-25, Suitability and "Know Your Customer"; 09-27, Member Public Offerings; 09-30, Credit Default Swaps; 09-34, Investment Company Securities; 09-35, Municipal Securities. Findings -- Notice 09-22: Sound supervisory practices require that a member firm monitor personal securities transactions outside of the firm by or for its associated persons. Notice 09-25: Suitability obligations and know-your customer obligations are critical to protecting investors. Notice 09-27: The offering of securities by a member firm or a control entity of the firm in a private placement raises conflicts of interest and has been an area of regulatory concern in recent years. Notice 09-30: Regulatory authorities are adopting measures to address system risk arising from credit default swaps (CDS), including risks to the financial system arising from the lack of a central clearing counterparty to clear and settle CDS; the SEC has approved a rule establishing an interim pilot program on margin requirements for CDS transactions. Notice 09-34: As part of the process to develop a new consolidated rulebook, FINRA is requesting comment on a proposed rule regarding the distribution and sale of investment company securities. Notice 09-35: FINRA recommends that firms engaged in municipal securities business review and, if necessary, modify their policies and procedures in light of changes to the Municipal Securities Rulemaking Board's (MSRB) Electronic Municipal Market Access system (EMMA) that take effect July 1, 2009, and changes to MSRB rules that went into effect June 1, 2009. FINRA also encourages firms to review the overall adequacy and effectiveness of their current policies and procedures for municipal securities activities generally, particularly those relating to the disclosure of material information, the suitability of recommendations to retail customers, and the general supervision of their municipal securities activities. Originality/value -- These are direct excerpts designed to provide a useful digest for the reader and an indication of regulatory trends. The FINRA staff is aware of this summary but has neither reviewed nor edited it. For further detail as well as other useful information, the reader should visit www.finra.org [ABSTRACT FROM AUTHOR]

Purpose – The purpose of this paper is to examine the role of derivative securities in over-pricing and market corrections. Design/methodology/approach – Daily market data from major indices are used to determine if the market was over-priced in 1987. Then, the literature is examined to show differences in research findings for what caused the bubble and its correction. Findings – Evidence is found that there was a market bubble in 1987. Examples are provided of how portfolio insurance can lead to the aggregation of traders' idiosyncratic errors and to an increase in the use of leverage, both of which can cause over-pricing. Research limitations/implications – Although the analysis is limited to equity markets, the findings should stimulate further research on the relationship between derivatives and asset pricing. Theoretically, derivative prices should be a function of asset prices, but it could be argued that the relationship is symbiotic. Practical implications – The findings may impact policy makers in establishing regulations regarding the use of derivatives. Moreover, asset managers may be able to better detect conditions of over-pricing. Originality/value – The paper demonstrates the important role of derivative securities in market prices. [ABSTRACT FROM AUTHOR]

In October 2008, the government of Argentina announced that the citizens’ privately owned retirement savings accounts (RSAs) would be nationalised. This article shows that contrary to the Kirchner government's assertions, the private savings system had great potential. Its performance may not have fully lived up to its initial expectations, but that was largely due to the adverse effects of underdeveloped securities markets, large informal sectors impeding widespread participation, intrusive investment regulation and poor implementation. Within its tight constraints, the private system worked better than the public PAYGO system. [ABSTRACT FROM AUTHOR]

Purpose - The purpose of this summary is to provide excerpts of selected Financial Industry Regulatory Authority (FINRA) regulatory notices issued from September to November 2008. Design/methodology/approach - The paper provides excerpts from FINRA Regulatory Notice 08-54, Guidance on Special Purpose Acquisition Companies; Regulatory Notice 08-62, Limit on Close Case Submissions; 08-66, Retail Foreign Exchange; and 08-70, FINRA Investigations. Findings - Notice 08-54: Special purpose acquisition companies (SPACs) are shell companies that raise capital in initial public offerings (IPOs) for the purpose of merging with or acquiring an operating company Notice 08-62: Effective November 24, 2008, FINRA will limit the circumstances under which parties may make submissions to arbitrators in closed cases. Notice 08-66: The retail over-the counter foreign currency exchange (retail forex) market is opaque, volatile and risky. Broker-dealers who engage in forex business with their retail customers must comply with the FINRA rules that apply to those activities. Notice 08-70: FINRA is issuing this guidance to apprise firms of the circumstances in which extraordinary cooperation by a firm or individual may directly influence the outcome of an investigation. Originality/value - These are direct excerpts designed to provide a useful digest for the reader and an indication of regulatory trends. The FINRA staff is aware of this summary but has neither reviewed nor edited it. For further detail as well as other useful information, the reader should visit www.finra.org [ABSTRACT FROM AUTHOR]

Copyright of Canadian Tax Journal / Revue Fiscale Canadienne is the property of Canadian Tax Foundation and its content may not be copied or emailed to multiple sites or posted to a listserv without the copyright holder's express written permission. However, users may print, download, or email articles for individual use. This abstract may be abridged. No warranty is given about the accuracy of the copy. Users should refer to the original published version of the material for the full abstract. (Copyright applies to all Abstracts.)

Purpose -- The purpose of this paper is to provide excerpts of selected Financial Industry Regulatory Authority (FINRA) Regulatory Notes issued in July and August 2008. Design/methodology/approach -- The paper provides excerpts from the June 2008 Supplement to the Options Disclosure Document; Regulatory Notice 08-38, SEC Emergency Orders on Short Selling; Regulatory Notice 08-39, Variable Insurance Products; Regulatory Not ice 08-41, Portfolio Margin Program; Regulatory Notice 08-42, SEC Rule 144 and TRACE Eligibility; and Regulatory Notice 08-43, Trade Reporting and Compliance Engine (TRACE) Findings -- The Orders and Guidance in Regulatory Notice 08-38 address the naked short selling of the securities of 19 public companies. Through Regulatory Notice 08-39, FINRA proposes to update and consolidate the rules governing member firm communications with the public about variable insurance products. Regulatory Notice 08-41 addresses margin requirements based on projected loss scenarios, and also discusses concentrated equity positions and day trading. Regulatory Notice 08-42 notes that once a security meets the definition of "TRACE-eligible security", all secondary market transactions in such securities are "reportable TRACE transactions". Regulatory Notice 08-43 describes additional data elements in real-time TRACE data that will identify transactions as either inter-dealer or customer transactions and, in customer transactions, whether the dealer is on the buy or sell side. Originality/value -- These are direct excerpts designed to provide a useful digest for the reader and an indication of regulatory trends. The FINRA staff is aware of this summary but has neither reviewed nor edited it. For further detail as well as other useful information, the reader should visit www.finra.org [ABSTRACT FROM AUTHOR]

Purpose - The purpose of this paper is to provide excerpts of selected Financial Industry Regulatory Authority (FINRA) Regulatory Notices issued from April to June 2008 and a sample of disciplinary actions during that period. Design/methodology/approach - The paper provides excerpts from FINRA Regulatory Notice 08-16, Third Party Research Reports; 08-17, Customer Complaint Reporting; 08-18, Unauthorized Proprietary Trading; 08-21, Partial Redemption of Auction Rate Securities; 08-22, Definition of Public Arbitrator; 08-27, Midleading Communications about Expertise; 08-30, Illiquid Investments; 08-31, Trading Ahead of Customer Orders; and 08-33, Minor Rule Violation Plan Amendment. Findings - Useful information may be found in each of these notices. Originality/value - The paper provides direct excerpts designed to provide a useful digest for the reader and an indication of regulatory trends. The FINRA staff is aware of this summary but has neither reviewed nor edited it. [ABSTRACT FROM AUTHOR]

The most recent reports about the financial derivatives market indicate that the Colombian and International financial derivatives OTC Markets trade a significantly higher volume as compared with the organized markets. The OTC market has gradually developed standard legal provisions and procedures, largely in part as a result of the consolidation of Master Agreements and the work of international associations such as the International Swaps and Derivatives Association (ISDA). Notwithstanding the worldwide standardization process, the Colombian OTC derivatives market shows a low level of standardization and convergence. This creates obstacles for the consolidation of the markets and increases the legal and economic risks for market participants. This article analyses the structure and evolution of Master Agreements; some of the main legal issues related to such agreements and their effects from a Colombian legal perspective; and the current status and prospects of the Master Agreements in Colombia. [ABSTRACT FROM AUTHOR]

Purpose -- The purpose of this paper is to describe regulatory activities since the initial regulatory actions between 2001 and 2003 in response to securities firm research analyst conflicts of interest that were identified after the "internet bubble." Design/methodology/approach -- The paper describes a number of important regulatory activities, including: interpretive activities, such as the 2004 Second Joint Research Memorandum; establishment of a new licensing requirement for research analysts; additional rulemaking, in the form of 2005 changes to the SRO Rules that are meant to tighten those rules; the December 2005 report of the NASD and NYSE studying the operation and effectiveness of prior regulatory actions, including the SRO Rules; enforcement actions against both firms' and research analysts' behavior; industry sweeps gathering information regarding industry practices in respect of debt research; and rulemaking for purposes of implementing interpretive guidance and Joint Report. Findings -- Following extraordinary and sweeping regulatory actions between 2001 and 2003, securities regulators have continued a high level of activity with respect to securities research. Research regulation stands as a hallmark for the current era of securities regulation for at least three reasons: it has displayed a wide range of regulatory tools including rulemaking, publication of interpretive guidance, "sweep" examinations, licensing, and enforcement, and has been largely "principles-based" rather than prescriptive in nature; it is marked by complexity: a web of SEC, SRO, and informal or "best practices" regulation now exists covering every aspect of securities research; and it is a cornerstone of an emerging regulatory theme of heightened and more detailed compliance for investment banking operations. Originality/value -- This is a valuable summary and analysis of seven years of regulatory activity on a complex issue by experienced securities lawyers [ABSTRACT FROM AUTHOR]

Abstract: A good legal knowledge representation system, capable of effectively providing investors with comprehensive legal knowledge, is needed for investors to prevent erratic behavior before investment decisions. This is especially important in Taiwan’s securities and futures markets because the majority of market participants are individual investors who have limited access to legal knowledge about markets. Besides, the construction of the knowledge representation has to be automatic in order to efficiently handle the fast-growing and changeable legal information. Thus, we use the GHSOM algorithm to present a content-based and easy-to-use map hierarchy for Chinese legal documents in the securities and futures markets in the Chinese language. Meanwhile, an enhanced topic selection module and a web-based user interface are also proposed. The maps can be browsed on the web site (http://synteny.iis.sinica.edu.tw/legalmap/). To evaluate the legal maps, we apply two approaches, namely a validity test and a task experiment. [Copyright &y& Elsevier]

This paper discusses two of the initiatives that have been embarked upon in an attempt to address the various concerns about legal certainty in today's dematerialised and intermediated securities markets: the Hague Convention on the Law Applicable to Certain Rights and the UNIDROIT draft Convention on Substantive Rules Regarding Intermediated Securities. The paper explores the development of these proposals, and looks at their likely acceptability to the market and their usefulness to practitioners. While political forces may determine whether or not the Hague and UNIDROIT conventions are necessary pieces of the puzzle in achieving legal certainty in the cross-border securities market, some solutions are needed if the cost of cross-border securities holding and settlement is to come down. [ABSTRACT FROM AUTHOR]

Purpose – This study attempts to examine the issues relating to corporate financial reporting of Chinese listed companies under specified institutional settings as companies with different share-categories are required to prepare annual reports under various General Accepted Accounting Principles (GAAP). Design/methodology/approach – This study selects Chinese companies that issue negotiable shares to examine whether corporate disclosure patterns are different under various institutional settings. Negotiable shares can be traded on stock exchanges and are divided into A-, B- and H-shares. The extent of corporate disclosure is obtained from the content analysis of annual reports for 191 sampled Chinese listed companies with various share categories. The association are hypothesized and tested between the level of corporate disclosure and the following corporate determinants: company size, profitability, auditor, leverage, industry and ownership structure. Findings – The extensive regulations and different standards influence on disclosures of companies with foreign investment participation and overseas listing status. By reconciliation of their annual reports according to the IFRSs or the GAAP of the listing country, these companies increased information disclosure voluntarily in order to enhance their reputation and credibility. Some corporate factors, such as company size, profitability and the size of auditor, have influenced the level of corporate disclosure in annual reports of domestic and foreign share-based companies. Ownership structure has positive impact on the level of disclosure for companies with domestic investors. Originality/value – This study advances knowledge of the influence that legislative circumstances and ownership structures can have on disclosure decisions made by management in their annual reports. This information is of high interest to domestic and foreign investors and regulators in understanding of financial reporting in Chinese listed companies. [ABSTRACT FROM AUTHOR]

The purpose of this paper is to provide a model linking enforcement of institutional environment and reform of corporate governance of firms. It is argued that in the context of weak enforcement environment in transition economies, institutional factors in securities markets are effective in shifting corporate governance model of the privatised firms towards a market-based model that ensures a sustainable economic performance. The empirical study in the Vietnamese securities market supports this argument. [ABSTRACT FROM AUTHOR]

We investigate the practical value of using graphical models to aid in two fundamental problems of group coordination: (1) belief aggregation and (2) risk sharing. We identify restrictive conditions under which graphical models can be useful in both settings. We show that the output of the logarithmic opinion pool (LogOP) can be represented as a Markov network (MN) or a decomposable Bayesian network (BN), and give an algorithm for doing so. We show that a securities market structured like a decomposable BN can support optimal risk sharing, if all agents have exponential utility and all of their Markov independencies coincide with the market structure. On the other hand, most of our results are negative, taking the form of impossibility theorems. We show that no belief aggregation function can maintain all independencies representable in a BN. Neither can an aggregation computation be decomposed into local computations on graph subsets. We show that computing query outputs of LogOP or the linear opinion pool (LinOP) is NP-hard. Except in fairly restrictive settings, structuring securities markets according to unanimously agreed upon independencies may be of no help in supporting optimal risk sharing because agents' behavioral independencies change as they engage in securities trade. [ABSTRACT FROM AUTHOR]

Purpose -- The aim of this article is to provide a description of the rule proposals and other events that preceded the SEC'S adoption of the 2005 Final Rule, a summary of the terms of the 2005 Final Rule, and a brief update regarding the status of the 2005 Final Rule. Design/methodology/approach -- Describes the SEC's 1999 proposed rule, "Certain Broker Dealers Deemed Not to Be Investment Advisers," questions that led to that proposed rule, commentary on that proposed rule regarding advisory activities for which broker-dealers receive special compensation, commentary regarding differences between the regulation of broker-dealers and the regulation of investment advisers, commentary regarding investors' understanding of the differences between broker-dealers and investment advisers, the five-year period without a formal rule, the 2005 Proposed Rule, the 2005 Final Rule, and concerns that remain after issuance of the 2005 Final Rule. Findings -- The Chairman of the SEC directed the SEC staff to investigate and report within 90 days on ways in which the policy issues raised by the 2005 Final Rule could be addressed. In addition to the investigation of issues raised by the 2005 Final Rule by the SEC staff, and although the 2005 Final Rule was adopted, to some extent, in response to the lawsuit filed against the SEC by the Financial Planning Association (the "FPA") in July 2004, the FPA filed a new lawsuit against the SEC on April 28, 2005. Originality/value -- A useful summary of the background and remaining issues related to the SEC'S 2005 Final Rule on application of the Adviser's Act to broker-dealers offering certain non-traditional brokerage programs. [ABSTRACT FROM AUTHOR]

Studies of early US growth traditionally emphasize real-sector explanations for an acceleration that is evident by the period 1815–1840. Interestingly, establishment of the nation''s modern financial structure predated by three decades the transportation improvements and widespread use of water- and steam-powered machinery that are thought to have triggered modernization. We argue that an innovative and expanding financial system, by providing debt and equity financing to businesses and governments as new technologies emerged, was central to early growth and modernization. To test the hypothesis, we employ a set of multivariate time series models that relate measures of banking and equity market activity to investment and business incorporations from 1790 to 1850. The results support the hypothesis of “finance-led” growth. Our new view is at odds with earlier views that emphasize the deficiencies rather than the advantages of the early US financial system. [Copyright &y& Elsevier]

The continuing evolution of the securities market infrastructure is a critical dimension of economic infrastructure development. This article examines the development of Eastern Europe's securities markets and the implications for investors. The region's varied trading systems, market structures, and regulatory environments are evolving, as the critical role the markets play in economic development and mobilization of capital are better understood. The current lack of standardization presents investors with a challenge when investing in the region's securities. Unless both domestic and international investors understand the securities markets' operations they will not provide Eastern European firms with the equity capital required for further growth. Harmonization of the rules of listing, trading, clearing and settlement of trades, reporting requirements and standards, surveillance and technical compatibility will serve to increase international investor interest in the region. In addition, the increased efficiency afforded by these market developments will provide firms with an incentive to raise capital through the domestic financial markets, at reduced costs. [ABSTRACT FROM PUBLISHER]

This paper discusses disclosures required of on-line broker-dealers, and recommends various internal measures that on-line broker-dealers should take to comply with securities trading regulations. On-line trading is transforming the relationship between investors and broker-dealers. While the services offered by on-line broker-dealers may be different from those offered by full-service brokers, the differences are diminishing, and both activities are subject to the same rules and regulations. A GAO report of May 2000, revealed that many on-line broker-dealers did not comply with disclosure requirements, resulting in complaints by customers who lost money or financial opportunities. As the SEC is strengthening its examinations, this article is helpful to firms that offer trading on-line to comply with disclosure requirements for investor protection. This article is especially helpful for internal auditors of these firms in implementing internal policy and procedures to ensure adequate disclosures and to mitigate risks of investors' litigation. [ABSTRACT FROM AUTHOR]

This paper presents the first known non-proprietary empirical examination of the relationship between Commercial Mortgage Backed Security (CMBS) pricing. CMBS prices are examined as a function of the "moneyness" of the default option, the age of the security, the interest rate, interest rate volatility, property price volatility, amortization features and yield curve slope utilizing a proprietary data set of monthly prices on 40 CMBS securities. We find that though the senior tranche CMBS in the sample are effectively immune from default loss per se, they are not immune from early return of principal and resulting duration shift implied by increasing default probabilities. Thus, they behave very much like residential mortgage backed securities in that discount security prices are positively related to explanatory variables associated with potential shifts in duration. As a result, senior tranche CMBS prices increase with explanatoryd factors that raise the likelihood of default such as property volatility and loan to value ratio whereas CMBS prices decrease with variables that lower default probability such as amortization. These empirical results fit well with existing theoretical models of multi-tranche CMBS pricing and models of commercial mortgage default and suggest that senior tranche CMBS may embody elements of risk that justify their seemingly rich spreads to similar duration corporate securities. [ABSTRACT FROM AUTHOR]

In the 1970s and 1980s, the three major securities markets in New York, London, and Tokyo underwent significant regulatory shifts that lowered national barriers to entry and liberalized the markets. Popular explanations point to- ward technologies, economic efficiencies, foreign policy pressures, the removal of controls on international capital flows, or international competition as unleashing forces promoting liberalization and breaching the regulatory levees. Such explanations generate expectations about behavior once the international pressures are unleashed. Significant changes in overseas participants' market behavior should be observable. International competitive pressures should produce convergence in regulatory and transaction costs across markets upon one of two equilibriums-one by competitive deregulations or another by harmonization through agreement Empirical tests produce results inconsistent with such expectations. Foreign participation does increase following the breach in the regulatory levees, but the unleashed demand cannot be described as a flood. Observable measures of market dynamics and transaction costs remain distinctive. The inconsistencies between results and expectations raise questions about explanations that emphasize increasing interdependence and international pressures as driving domestic political and economic changes. [ABSTRACT FROM AUTHOR]

This article examines the relationship between the phenomenon known as 'globalization', on the one hand, and the regional integration process undertaken by European Union (EU) member states, on the other. Bearing in mind that the EU single market programme was a more deliberate and radical act of integration than the more haphazard globalization process, the article argues that the relationship between the two is a complex mix of convergence and conflict. The argument is applied to the financial services sector, and in particular the securities industry. The first conclusion is that the EU integration process is compatible with global financial integration. The EU single financial area has not led, and will not lead, to the emergence of a separate European 'bloc'. Indeed, on a number of regulatory issues, the combination of globalization and EU integration has induced convergence and a degree of harmonization between the EU and other jurisdictions such as the United States and Japan. The second conclusion is, however, that this progress towards convergence and harmonization is inherently conflictual and is currently blocked on the key issue of capital adequacy for securities firms. The US, supported by Canada and Japan, has resisted convergence, or indeed compromise, with what it views as unduly lax EU capital standards. Internal EU dynamics, domestic considerations within the US, market-driven pressures and the temptations of regulatory arbitrage have all contributed to the conflictual aspects of the convergence process. The EU and the Basle banking supervisors have now accepted the EU approach to capital adequacy, and the pressure is on the US regulatory authorities to conform to these lower standards or take the risk that trading activity will migrate to where standards, and therefore transaction costs, are lower. [ABSTRACT FROM AUTHOR]

The article offers information about changes to the Rules of the Market Arbitration Panel (Câmara de Arbitragem do Mercado) decided by the Brazilian Exchange in 2012. Topics include environmental disputes under the Market Panel, changes to procedures of the Market Panel, and the potential appointment of an urgency arbitrator.

Purpose -- The purpose of this paper is to explain the new "Same-Day Clearance Option" FINRA has made available to issuers and members effective March 1, 2010. Design/methodology/approach -- The paper explains the background of pre-offering review of registered securities offerings for compliance with FINRA's regulations and the increased volume of shelf takedown offering submissions that led FINRA to offer the Same-Day Clearance Option; outlines the three same-day clearance methods, base filing only, takedown filing, and concurrent based and takedown filing; and discusses the effect the Same-Day Clearance Option will have on issuers and members. Findings -- Since September 2008, the financial markets have been extremely volatile, causing many issuers' market capitalizations to fall and the number of shelf takedown offering submissions to increase accordingly, placing a greater burden on FINRA and causing a delay in the review and approval process for a number of such offerings. Practical implications -- With this change, issuers will be better able to take advantage of market conditions when they prove amenable to offerings, and members will be better positioned to market and consummate an offering without the time constraints presented by the traditional FINRA approval process. Originality/value -- The paper provides practical guidance from experienced securities lawyers. [ABSTRACT FROM AUTHOR]