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Applicability of the reporting requirement under Rule 3070(a)(8) to a non-securities related automobile insurance settlement exceeding $15,000.
Applicability of NASD Rule 3030 to an associated person filing a membership application with the NASD to form a new broker/dealer.
Applicability of NASD rules to a member's use of a translator for group retirement plan enrollment presentations.
October 18, 2001
Mr. William E. Floria
President
House of Securities Company
12 West Church Street
Frederick, MD 21701
Re: Exemption Request from Fidelity Bonding Requirements
Dear Mr. Floria:
Rule 11210(a)(3) does not prohibit a firm from effecting the requirements of the provision electronically, but the firm is responsible for the accuracy and proper functioning of the computer program.
An individual who processes transactions by communicating orders to the member’s clearing firm, which then calls or electronically communicates with the contra-side of the transaction, is not involved in the execution of transactions for purposes of Rule 1032(f) and thus is not required to be Series 55 registered.
Relief granted to banks to facilitate an orderly and efficient transition of employees from a bank into a broker/dealer to comply with the Financial Modernization Act of 1999.
Application of Rule 2320(g) and Rule 3110(b) to quotations displayed in the Electronic Quotation Service (prior to the adoption of proposed Rule 6630).
A member firm may pay continuing commissions to a former registered representative who is no longer in the securities business provided the conditions of NASD IM-2420-2 are satisfied, and further, that such payments are made in compliance with SEC "no-action" letters addressing the permissibility of those payments under Section 15(a) of the Securities Exchange Act of 1934.
Applicability of Rule 3230 to a three-party clearing agreement.
Letter addresses circumstances under which persons must report events involving a fixed annuity insurance product.
All Letters of Caution represent a determination that a violation has occurred, either of an NASD rule or a rule of the Securities and Exchange Commission over which NASD Regulation has jurisdiction to enforce. A Letter of Caution that results from a finding in a disciplinary proceeding initiated under the Rule 9200 Series of the NASD Code of Procedure is a sanction within the meaning of Procedural Rule 8310(a)(6), but a staff-issued Letter of Caution is not a sanction within the meaning of Procedural Rule 8310(a)(6).
Permissible activities of a foreign associate.
Permissibility of electronic signatures under NASD Rules 3010(d) and 3110(c)(1)(C).
Proposed employee leasing arrangement does not violate Rule 2420.
Payments by an investment adviser to broker-dealers in the form of rights to receive cash compensation upon the occurrence of specific corporate events (e.g., initial public offering of shares of the adviser) do not constitute "non-cash compensation" under NASD Rule 2830(l).
The limited supervisory functions that can be properly delegated to registered representatives also may be assigned to persons registered as Foreign Associates under NASD Rule 1100. Foreign Associates, however, may not perform the functions that require a principal registration.