Guidance

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Regulatory and Compliance Alerts (RCA)
Regulatory & Compliance Alert - Winter 2000
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December 01, 2000
Interpretive Letter
Interpretive Letter to Angela Coronado, Brecek & Young Advisors, Inc.
Collection of customer information from account application forms.
November 27, 2000
Interpretive Letter
Interpretive Letter to Ms. Joanne Ferrari, Weeden & Co., L.P.
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
Interpretive Letter to Mr. Alan E. Sorcher, Securities Industry Association & Ms. Sarah A. Miller, ABA Securities Association

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
Interpretive Letter to Justine Rusin, Merit Capital Associates, Inc. (Use of Negative Response Letters)
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
Interpretive Letter to Eric A. Arnold, Esq., Sutherland Asbill & Brennan LLP
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
Name Not Public
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
Interpretive Letter to Janna R. Severance, Esq., Moss & Barnett
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
Interpretive Letter to Allan H. Pessin, Securities Compliance Consultants Inc.
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
Interpretive Letter to Leslie U. Harris, East/West Securities Co.

NASD Regulation Inc.'s review of membership names.

September 28, 2000
Interpretive Letter
Interpretive Letter to Kathleen A. Wieland, William Blair & Company

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)
Regulatory & Compliance Alert - Fall 2000
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September 01, 2000
Exemptive Letter
Exemptive Letter regarding Rule 2710, Issued by the Corporate Financing Department
Summary of Exemption Decision Re: Rule 2710 Issued by Corporate Financing Department
August 31, 2000
Interpretive Letter
Interpretive Letter to Thomas E. Hellings, Securities America, Inc.
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
Interpretive Letter to Ms. M. LaRae Bakerink, Pacific American Securities, LLC
Activities requiring registration as an Equity Trader.
August 14, 2000
Interpretive Letter
Interpretive Letter to Mr. Edward Balsmann, Morgan Keegan & Company, Inc.
Supervisory activities requiring registration as an Equity Trader.
August 14, 2000
Interpretive Letter
Interpretive Letter to David M. Rappaport, Esq., INVESTACORP Inc.
Permissible activities for a Series 6 Representative (Limited Representative - Investment Company and
August 11, 2000
Exemptive Letter
Exemptive Letter regarding Rule 2710, Issued by the Corporate Financing Department
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
Interpretive Letter to Alan Feldstein, Esq., Development Corporation for Israel
Application of Customer Account Information and Suitability requirements to member selling one type of security to narrow target audience.
August 04, 2000
Interpretive Letter
Interpretive Letter to Fiona Kaufman, Esq., SVB Securities, Inc.
Satisfying third party download provider requirements of the SEC's rules for electronically stored records.
July 24, 2000
Interpretive Letter
Interpretive Letter to Joanne Ferrari, Weeden & Co., L.P.
Permissible activities of a Series 11 Representative (Assistant Representative/Order Processing).
July 19, 2000
Interpretive Letter
Interpretive Letter to Stephen M. Vine, Esq., Akin, Gump, Strauss, Hauer & Feld, L.L.P.
Activities requiring registration as an Equity Trader.
July 19, 2000
Interpretive Letter
Interpretive Letter to Kathleen A. Wieland, William Blair & Company, L.L.C.

Use of Modified Corporate Name

July 05, 2000
Exemptive Letter
Name Not Public
Exemptive relief is granted based on the following considerations: (1.) the de minimis nature of the Proposed Hire’s Contribution made more than one year ago; (2.) the Contribution was made by an individual who has never been employed in the municipal securities business.
June 30, 2000
Interpretive Letter
Interpretive Letter to Robinson Markel, Esq., Rosenman & Colin, LLP

Adequate documentation of reasonable efforts to borrow, standing alone, would not constitute a circumstance sufficient to mitigate the inability to deliver securities on settlement date where a member has relied upon an "Easy to Borrow" or "Hard to Borrow" list.

June 20, 2000