FINRA Proposes Conflict of Interest Restrictions on Former FINRA Employees

FINRA proposed the adoption of a conflict of interest rule for former FINRA employees. Rule 9910 ("Post-Employment Conflict of Interests Restrictions; Nonpublic Information") would prohibit:

• any former FINRA officer from making certain communications to, or appearances before, FINRA for one year after the termination of his or her employment;
• any former FINRA employee from making certain communications to, or appearances before, FINRA at any time in a matter that involves a specific party with which the employee was "personally and substantially involved" during his or her employment;
• any former FINRA employee from making certain communications to, or appearances before, FINRA for two years in a matter involving a specific party that was under the employee's "official responsibility" during the last year of his or her employment; and
• any current or former FINRA employee from disclosing any nonpublic information obtained during the duration of his or her employment with FINRA, unless the disclosure is authorized by FINRA or is required or protected by law.