Interpretive Letters

 
Interpretive letters provide guidance on the staff's views as to the application of particular FINRA rules under specific circumstances. Members, associated persons, and their counsel should consider seeking further guidance regarding their own unique circumstances.

Date Title Related Rule Core Topic
Mar 26, 2010 Interpretive Letter to William D. Edick, Pickard and Djinis LLP FINRA Rules 7410-7470 (OATS)
Jul 09, 2008 FINRA Office of General Counsel (Auction Rate Securities) NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Auction Rate Securities, Illiquid Investments, Advertising Regulation
May 15, 2008 Letter from FINRA Office of General Counsel, May 15, 2008 NASD Rule 2510 - Discretionary Accounts Mergers Acquisitions and Business Transfers
Dec 28, 2007 Interpretive Letter to Richard Schultz, Triad Securities Corp. NASD Rule 2420 - Dealing with Non-Members
Dec 19, 2007 Interpretive Letter to Mr. Julian Rainero, Bracewell & Giuliani LLP NASD Rules 6950-6957 (OATS)
Dec 17, 2007 Interpretive Letter to Amal Aly, SIFMA (Reasonable and Customary Bereavement Gifts) NASD Rule 3060 - Influencing or Rewarding Employees of Others Gifts, Gratuities and Non-Cash Compensation
Sep 28, 2007 Interpretive Letter to Dan Danborn, Society of Certified Senior Advisors NASD Rule 2210 - Communications with the Public Senior Investors, Senior Designations, Advertising Regulation
Sep 06, 2007 Interpretive Letter to Tamara K. Salmon, Investment Company Institute NASD Rule 2210 - Communications with the Public Business Cards, Letterhead, Advertising Regulation
Nov 30, 2006 Interpretive Letter to Evan Charkes, Citigroup Global Markets, Inc. NASD Rule 3010 - Supervision Qualification Exams, Supervision
Oct 06, 2006 Interpretive Letter to Alan M. Wolper, Esq., Sutherland Asbill & Brennan LLP NASD Rule 2460 - Payments for Market Making
Sep 28, 2006 Interpretive Letter to Steven K. McGinnis, Loring Ward Securities, Inc. NASD Rule 2830 - Investment Company Securities Gifts, Gratuities and Non-Cash Compensation, Public Offerings
Aug 15, 2006 NASD Office of General Counsel, Regulatory Policy and Oversight NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Advertising Regulation, Supervision
Aug 01, 2006 Interpretive Letter to Eileen Ryan, Esq., Securities Industry Association, and Sarah Starkweather, Esq., The Bond Market Association NASD Rule 2211 - Institutional Sales Material and Correspondence Public Offerings, Free Writing Prospectus, Advertising Regulation
Jun 02, 2006 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation
Dec 12, 2005 Interpretive Letter to Mr. Alan E. Sorcher, Securities Industry Association & Ms. Sarah A. Miller, ABA Securities Association NASD Rule 1070 - Qualification Examinations and Waiver of Requirements Qualification Exams
Mar 16, 2005 Interpretive Letter to Tamara K. Salmon, Investment Company Institute NASD Rule 2510 - Discretionary Accounts Public Offerings, Mergers Acquisitions and Business Transfers
Feb 03, 2005 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation, Customer Account Transfers
Jan 26, 2005 Interpretive Letter to George T. Simon, Foley & Lardner, LLP NASD Rule 2510 - Discretionary Accounts Mergers Acquisitions and Business Transfers
Nov 29, 2004 Interpretive Letter to Therese Squillacote, ING Financial Advisers, LLC NASD Rule 2210 - Communications with the Public Filing Requirements, Advertising Regulation
Nov 10, 2004 Interpretive Letter to Michael R. Trocchio, Esq., Bingham McCutchen LLP NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation
Nov 08, 2004 NASD Office of General Counsel, Regulatory Policy and Oversight NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation, Customer Account Transfers
Oct 20, 2004 Interpretive Letter to Barry Harris, Banc of America Investment Services, Inc. (Use of Negative Response Letters) NASD Rule 2110 - Standards of Commercial Honor and Principles of Trade Negative Response Letters, Advertising Regulation, Mergers Acquisitions and Business Transfers
Sep 14, 2004 Interpretive Letter to Budge Collins, Collins/Bay Island Securities NASD Rule 2210 - Communications with the Public Related Performance, Advertising Regulation
Aug 20, 2004 Interpretive Letter to Mark W. Riepe, Charles Schwab & Co., Inc. NASD Rule 2711 - Research Analysts and Research Reports Qualification Exams, Research Reports, Advertising Regulation, Research Analyst Rules
Aug 05, 2004 Interpretive Letter to Mr. Alan E. Sorcher, Securities Industry Association & Ms. Sarah A. Miller, ABA Securities Association NASD Rule 1070 - Qualification Examinations and Waiver of Requirements Qualification Exams