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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

Applicability of Rule 3230(a) to secondary or sub-clearing arrangements with foreign securities firms.

July 23, 1999
Exemptive Letter
June 14, 1999
Guidance

Rule 3060 does not limit ordinary and usual business entertainment provided by a member or its associated persons to the member's clients and their guests.

June 10, 1999
Regulatory and Compliance Alerts (RCA)
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June 01, 1999
Guidance

Non-cash compensation sales contest permissible under Conduct Rule 2820(h) where member sells only one variable annuity and one variable life product and appropriate records are maintained.

May 20, 1999
Guidance

A sales incentive program can combine non-conforming criteria based on sales prior to January 1, 1999 with conforming criteria based on sales subsequent to January 1, 1999 for incentives to be provided prior to June 30, 2000.

March 31, 1999
Interpretive Letter

A partnership registering as a broker/dealer, which will be trading only for its own account, has no customers for purposes of Rule 2330(f).

March 15, 1999
Interpretive Letter

Exemptive request denied: the OATS Rules do not provide NASD Regulation with the authority to grant exemptions from any of the OATS requirements.

March 08, 1999
Interpretive Letter

The Firm Quote Rule (SEC Rule 11Ac1-1) requires a member firm to execute trades submitted to it by a firm that has exceeded its Super Cap status unless: (i) the firm had failed to settle on a trade the previous day, (ii) ACT has publicized that the firm has exceeded its Super Cap status and its clearing firm is not willing to honor the trade, or (iii) the firm's clearing firm has deleted the clearing relationship.

March 08, 1999
Interpretive Letter
Rule 2220 was intended to apply only to standardized options; therefore, advertisements, educational material and sales literature regarding conventional options need not be submitted to the Department for pre-use review and approval. However, advertisements, educational material and sales literature regarding conventional options remain subject to the general standards in both Rules 2210 and 2220 that prohibit untrue, false or misleading statements.
March 05, 1999
Regulatory and Compliance Alerts (RCA)
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March 01, 1999
Interpretive Letter

Scope of permissible functions of a Compliance Registered Operations Principal (CROP).

February 17, 1999
Interpretive Letter

Short Sale Netting Requirements and Aggregation Units

February 08, 1999
Interpretive Letter
NASD members and associated persons who are required to use hypothetical illustrations under New York State's Regulation 60 with respect to internal and external replacements of life insurance and annuity contracts, would not be prevented under NASD Rule 2210 from using such illustrations. However, any use beyond what is required by Regulation 60 may require the illustrations to be filed with NASD Regulation as sales literature.
February 05, 1999
Interpretive Letter
Entity should obtain a "no action" letter from the SEC before NASD Regulation will determine whether payment of non-transaction-based compensation from a member to a non-member for administrative and clerical services under a preferred alliance agreement would violate Rule 2420.
January 29, 1999
Interpretive Letter
Factors that may determine whether research personnel are required to be registered include their communications with customers, making of recommendations, accepting or executing orders for the purchase or sale of securities, and method of compensation.
January 27, 1999
Interpretive Letter
This letter grants an exception to the OATS requirements to submit Cancel/Replace Reports and Route Reports for modifications made by a trader to orders routed to an ECN for handling/execution. Customer modifications to orders are specifically excluded from the interpretation.
January 06, 1999
Interpretive Letter
IM-2420-2, the "Continuing Commissions Policy," does not apply to the receipt by a terminated broker/dealer of commissions generated by its former registered persons after they have transferred to a new firm. Rule 2420 would further apply to prohibit the receipt of the commissions by the non-member broker/dealer.
December 09, 1998
Interpretive Letter
IM-2420-2, the "Continuing Commissions Policy," does not apply to the receipt by a terminated broker/dealer of commissions generated by its former registered persons after they have transferred to a new firm. Rule 2420 would further apply to prohibit the receipt of the commissions by the non-member broker/dealer.
December 09, 1998
Interpretive Letter
Broker/dealer should seek SEC interpretative advice regarding "override" payments to insurance company for securities transactions executed by registered representatives who are associated with both the broker/dealer and the insurance company.
December 07, 1998
Interpretive Letter

Secondary market trading in Select Sector SPDR Funds does not violate Rule 2830(c) and (g).

December 07, 1998
Regulatory and Compliance Alerts (RCA)
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December 01, 1998
Interpretive Letter
Application of the OATS Rules to: partial executions, bunched orders, pegged orders, and negotiated orders.
October 26, 1998
Interpretive Letter
In a request for interpretive guidance, a member asks if NASD Rules prohibit a member from paying finders or referral fees to CPAs that are not registered as associated persons.
September 16, 1998
Regulatory and Compliance Alerts (RCA)
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September 01, 1998