On September 15, the Financial Industry Regulatory Authority (FINRA) issued guidance on public offerings, outlining the obligations of FINRA member firms under FINRA Rules 5110, 5121 and 2310. Among other things, FINRA members (1) must file documents and other information on a timely basis in connection with public offerings, (2) cannot participate if the underwriting terms and arrangements are unfair or unreasonable, (3) must prominently disclose the nature of any conflicts of interest and (4) if participating in the distribution of shares in a Direct Participation Program or an Unlisted Real Estate Investment Trust, must comply with additional compensation and disclosure requirements as described in FINRA Rule 2310.

The guidance is available here.