Structured products issuers using pre-inception index performance (PIP) data in communications with retail investors will be in breach of Finra Rule 2210(d) , according to a guidance letter published by the US Financial Regulatory Authority (Finra) at the end of April. Finra's new guidance on the use of back-tested index performance in institutional communications was released in a letter to a distributor of exchange-traded products (ETPs), highlighting that the use of PIP data in institutional