On September 5, the SEC approved new FINRA rule 5123 requiring each member firm that sells an issuer’s securities in a private placement to file with FINRA a copy of any private placement memorandum, term sheet or other offering document within 15 days of the date of sale.  The rule exempts some private placements sold solely to qualified purchasers, institutional purchasers and other sophisticated investors.  The rule becomes effective on December 3.  FINRA Notice and Rule.