Family Offices Included as ‘Investment Advisers’ Under IPO Allocation Rule 5131(b)

On May 9, 2017, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued an interpretive letter (the “Letter”)[1] regarding its IPO allocation rule 5131(b) and its exception 5131.02(b) (the “IPO Allocation Rule”, or “Rule”).[2]   As described below, the Letter includes family offices (“Family Offices”)[3] under exception 5131.02(b)’s meaning of “investment…