Guidance
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Interpretive Letter
Imposition of a fee to customers for redemption of mutual funds, where the fee initially is charged to the broker/dealer by clearing firms, is generally not prohibited under NASD rules if the fee is reasonable and customers are given adequate notice.
December 22, 2000
Exemptive Letter
An exemption is granted based on consideration of the MSRB’s published interpretation of Rule G-37 regarding mergers of corporations in the municipal securities industry3 and on your representation that Individual will not be engaged in helping Firm A obtain municipal securities business or engaged in municipal securities representative activities before September 24, 2001, when the two-year ban under Rule G-37 would otherwise expire.
December 18, 2000
Interpretive Letter
NASD Rule 1060 exempts from NASD registration requirements individuals registered as floor members with a national securities exchange whose investment banking or securities functions are related solely and exclusively to effecting transactions on the floor of a national securities exchange. Staff interprets "floor members" for purposes of the rule to include individuals working on the floor of the NYSE and registered with the NYSE as sales assistants.
December 11, 2000
Regulatory and Compliance Alerts (RCA)
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December 01, 2000
Interpretive Letter
Collection of customer information from account application forms.
November 27, 2000
Interpretive Letter
Inside directors of broker/dealers must register as principals if they wish to participate in the day-to-day conduct of members' securities businesses and the implementation of corporate policies related to such businesses.
November 01, 2000
Interpretive Letter
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.
October 27, 2000
Interpretive Letter
The use of negative response letters to transfer customers from one introducing broker to another may conflict with a member's obligation to observe high standards of commercial honor and just and equitable principles of trade.
October 16, 2000
Guidance
A member is not an "affiliated member" of an insurance company for purposes of Rule 2820(g)(4)(D) where no control relationship exists between the entities.
October 12, 2000
Exemptive Letter
Exemptive relief is granted based on the following considerations: (1.) the de minimis nature of the Contribution mitigates the probability that the payment will improperly influence issuer officials; (2.) the Contribution was made by an individual who has never been employed in the municipal securities business.
October 10, 2000
Interpretive Letter
Outside directors of broker/dealers must register as principals if they wish to participate in the day-to-day conduct of members' securities businesses and the implementation of corporate policies related to such businesses.
October 02, 2000
Interpretive Letter
Outside directors of broker/dealers must register as principals if they wish to participate in the day-to-day conduct of members' securities businesses and the implementation of corporate policies related to such businesses.
October 02, 2000
Interpretive Letter
NASD Regulation Inc.'s review of membership names.
September 28, 2000
Interpretive Letter
A member that is an investment adviser may pay a non-member certain fees and not violate Rule 2420 if the fees paid to the non-member (a) strictly follow the requirements of Rule 206(4)-3 under the Investment Adviser's Act of 1940; and (b) are paid from fees and other income that the member has received in its capacity as an investment advisor.
September 27, 2000
Regulatory and Compliance Alerts (RCA)
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September 01, 2000
Exemptive Letter
Summary of Exemption Decision Re: Rule 2710 Issued by Corporate Financing Department
August 31, 2000
Interpretive Letter
Application of Suitability and Supervision requirements to recommendations of new variable annuity bonus products to existing variable annuity bonus products customers.
August 31, 2000
Interpretive Letter
Supervisory activities requiring registration as an Equity Trader.
August 14, 2000
Interpretive Letter
Activities requiring registration as an Equity Trader.
August 14, 2000
Exemptive Letter
Exemption granted to extend exemption previously granted from Rule 2720(l), to [Firm] on June 14, 1999 to include offerings of warrants and purchase contracts and to units consisting of debt securities, warrants, and/or purchase contracts.
August 11, 2000
Interpretive Letter
Permissible activities for a Series 6 Representative (Limited Representative - Investment Company and
August 11, 2000
Interpretive Letter
Application of Customer Account Information and Suitability requirements to member selling one type of security to narrow target audience.
August 04, 2000
Interpretive Letter
Satisfying third party download provider requirements of the SEC's rules for electronically stored records.
July 24, 2000
Interpretive Letter
Activities requiring registration as an Equity Trader.
July 19, 2000
Interpretive Letter
Permissible activities of a Series 11 Representative (Assistant Representative/Order Processing).
July 19, 2000