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5 A B C D E F G H I L M N O P Q R S T V
Interpretive Letter
Series 7 registered representatives are not required to register under Series 55 as equity traders based solely on the fact that they perform the clerical function of entering customer phone orders into the same routing system that customers could use to enter orders electronically. The Series 7 representatives, under the facts described in the letter, would not provide any advice to the customers, including advice on possible paths or methods of execution.
April 19, 2001
Interpretive Letter
Intra-firm account transfers must be conducted in a manner consistent with a member's obligation to observe high standards of commercial honor and just and equitable principles of trade.
March 18, 2001
Guidance

NASD Rule 3060(a) does not apply to reimbursements by a registered representative of his or her client's expenses when the reimbursement is unrelated to the business of the client's employer.

March 15, 2001
Interpretive Letter

Rebate of SEC Rule 12b-1 fees and commissions to non-member retirement plan and its participants will not violate NASD Rule 2420 if the SEC determines that the rebate recipients are not required to register as broker/dealers.

March 08, 2001
Guidance

Reminder that offerors may not pay for golf outings, tours or other forms of entertainment while at a meeting it sponsors for the purpose of training or education. This letter was sent by NASD Regulation to a number of members that manufacture and sponsor variable and investment company products and to certain trade associations.

March 07, 2001
Guidance

Reminder that offerors may not pay for golf outings, tours or other forms of entertainment while at a meeting it sponsors for the purpose of training or education. This letter was sent by NASD Regulation to a number of members that manufacture and sponsor variable and investment company products and to certain trade associations.

March 07, 2001
Regulatory and Compliance Alerts (RCA)
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March 01, 2001
Interpretive Letter
Boston Stock Exchange (BSE) specialists effecting transactions in NYSE securities through ECNs, or Nasdaq securities through the UTP Plan, from terminals located on the floor of the BSE, are effecting transactions on the floor of the BSE for purposes of NASD Rules 1032(f) and 1060.
February 13, 2001
Interpretive Letter

A person who processes agency transactions by communicating all orders to another 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.

January 29, 2001
Interpretive Letter

NASD Regulation does not provide interpretive guidance on the appropriateness of a commission or mark-up schedule under Rule 2440, relating to fair prices and commissions, and the related mark-up policy, IM-2440. Further, NASD Regulation does not provide any assurance in the interpretive process that a firm's absolute reliance on a schedule for determining a commission or a mark-up is appropriate.

January 23, 2001
Interpretive Letter
Order entry personnel are not required to register under Series 55 as equity traders based solely on the fact that they enter orders into routing systems, which send the orders to clearing firms for execution. Also, not all persons to whom equity traders report need to be Series 55 registered.
January 19, 2001
Interpretive Letter

Secondary market trading in streetTracks Series Funds does not violate NASD Rules 2830(c) and (g).

January 16, 2001
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