NASD® has taken disciplinary actions against the following firms and individuals for violations of NASD rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
Summary
In support of the Securities and Exchange Commission’s re-proposal to amend Rule 15b9-1 under the Securities Exchange Act of 1934,1 FINRA is issuing this Notice to re-open the comment period for Regulatory Notice 15-13. Rule 15b9-1 currently provides proprietary trading firms with an exemption from membership in a national securities association. If the SEC re-proposal is adopted, the
Regulatory Notice
Notice Type
Request for Comment
Referenced Rules & Notices
Exchange Act Sections 3(a)(10), (12), (29) and (42)
FINRA Rules 0150, 2010, 2241, 2242, 2320, 4370, 5240, 5250, 5270, 5280, 5310, 5320, 6420 and 6710
NASD Rules 1021, 1022, 1031, 1032 and 1050
SEA Regulation NMS
Registered representatives who are not qualified to engage in investment banking activities may, subject to specified conditions, receive transaction-based compensation for referring existing brokerage clients that express an interest in investment banking transactions.
Dear Mr. Markunas:
This is in response to your correspondence dated June 15, 2020, in which you request interpretive guidance
As requested by the Department of Treasury (Treasury), the National Association of Securities Dealers, Inc. (NASD®) provides members with information from the Office of Foreign Assets Control (OFAC) about persons and entities identified as "Specially Designated Nationals and Blocked1 Persons" and about other OFAC regulations. On December 9, 1997, OFAC amended its regulations to require
Frequently Asked Questions (FAQ) covering reporting of corporate and agencies debt, reporting of mortgage and asset backed securities to the Trade Reporting and Compliance Engine (TRACE)
<p>Direct payments of securities-based compensation by a member to the associated persons of another member are not permitted under NASD Rules 2820(g) and 2830(l) absent an SEC No-action letter or interpretive release. Further, proposed arrangement may require dual registration of associated persons.</p>
<p>Direct payments of securities-based compensation by a member to the associated persons of another member are not permitted under NASD Rules 2820(g) and 2830(l) absent an SEC No-action letter or interpretive release. Further, proposed arrangement may require dual registration of associated persons.</p>
GUIDANCE
Life Settlements
SUGGESTED ROUTING
KEY TOPICS
Internal Audit
Legal and Compliance
Retail
Senior Management
Variable Life Settlements
Variable Insurance Policies
Suitability
Best Execution
Rule 3010
Executive Summary
Sales of existing life insurance policies to third parties—often
referred to as "life settlements"—have grown exponentially in
recent years, and
(a) Requirements for Public Offerings
(1) General
(A) No member or person associated with a member shall participate in a public offering in which the terms and conditions relating thereto, including the aggregate amount of underwriting compensation, are unfair or unreasonable pursuant to this Rule or inconsistent with any By-Law or any rule or regulation of FINRA.
(B) Any member acting as a
