TY  - JOUR
AB  - Purpose To explain the significance of a recently issued interpretive letter in which FINRA staff agreed to permit the use of pre-inception index performance data by passively managed, registered open-end investment companies.Design/methodology/approach FINRA recently issued an interpretive letter extending previously issued guidance by permitting passively managed open-end registered investment companies including separately-managed series of a business trust to use pre-inception index performance data in Institutional Communications.Findings The 2019 Letter is an important shift in how FINRA staff views PIP data in Institutional Communications by acknowledging that passively managed open-end funds should be treated in a similar manner as passively managed exchange-traded funds. This shift will be a welcome development for FINRA member firms wishing to include PIP data in marketing materials for the passively managed open-end funds they distribute.Originality/value Practical guidance from experienced investment management and broker-dealer lawyers.
VL  - 20
IS  - 3
SN  - 1528-5812
DO  - 10.1108/JOIC-04-2019-0026
UR  - https://doi.org/10.1108/JOIC-04-2019-0026
AU  - Kerr Richard F.
AU  - Rogers Matthew J.
PY  - 2019
Y1  - 2019/01/01
TI  - FINRA relaxes restrictions on pre-inception performance data
T2  - Journal of Investment Compliance
PB  - Emerald Publishing Limited
SP  - 6
EP  - 9
Y2  - 2024/04/19
ER  -