<p>When a member exchanges TRACE-eligible securities for a Creation Unit of an exchange-traded fund ("ETF"), the transfer of TRACE-eligible securities is not required to be reported to TRACE. Similarly, when a member redeems a Creation Unit of an ETF and receives TRACE-eligible securities, their acquisition is not required to be reported to TRACE.</p>
<p>Transactions in certain medium term notes, purchased and re-sold to retail customers during the offering period, should not be reported to TRACE as set forth in Rule 6230(e)(1) because the transactions are part of a primary distribution.</p>
<p>For purposes of reporting to TRACE only, a member may enter only <i>bona fide</i> commissions in the "commission" field and may charge a commission only in specified transactions.</p>
This request for exemptive relief is granted based on the Firm's representation that the individual did not engage in the solicitation of municipal securities business, as defined by MSRB Rule G-37, the imposition by the Firm of extensive Firm-wide information barriers on certain municipal securities business communications, prohibition of, for a specified period of time, the individual's solicitation of new municipal securities business, a Firm commitment to conduct training or re-training for all Firm MFPs and new hire MFPs, including an on-going annual educational effort, a review of existing Firm procedures and the development of necessary enhancements.
This request for exemptive relief is granted based on the Firm's representation that the Contributions were made prior to the individual being employed by the Firm, and that the individual has never engaged in municipal securities business, as defined by MSRB Rule G-37, the return of the Contributions, and the extensive information barriers and compensation restrictions.
This request for exemptive relief is granted based on the representations that the Contributions were made prior to the individual's employment with the Firm, and the individual has never been involved in municipal securities business as defined by MSRB Rule G-37. Additionally, the Firm has agreed to institute information barriers and compensation restrictions, and the contributions have been returned.
This request for exemptive relief is granted based on the Firm's representation that the Contributions were made prior to the individual's employment with the Firm, and that the individual was never engaged in municipal securities business, as defined by MSRB Rule G-37 ("Rule"), and the individual has never solicited municipal securities business from the City or City agencies of whom the Contribution recipients are issuer officials. The Firm agreed to institute certain information barriers, the individual will, for a period of time, be prohibited from soliciting municipal securities business as defined by the Rule, and the individual may not receive any compensation derived directly or indirectly from municipal securities business from City or certain City agencies for a period of time.
This request for exemptive relief is granted based on the Firm's representation that the contributor has never solicited municipal securities business, as defined by MSRB Rule G-37, from the State or entities or agencies connected with the State of whom the contribution recipient is considered to be an issuer official, the Contribution was returned, and representations that the Firm has imposed certain limitations on the individual's municipal business solicitation, and receipt of compensation from the Firm's municipal securities business with the State or State agencies.
The staff granted an exemption from NASD Rule 2790 in connection with new issue offering where all decisions regarding the allocation of shares in the offering are determined at the sole discretion of the issuer.February 3, 2006 Bruce E. Lee, Esq.208 North 29th StreetSuite 221P.O. Box 1222Billings, MT 59103 Re: Request for Exemption from Rule 2790 Dear Mr. Lee
The staff granted an exemption from NASD Rule 2790 in connection with new issue offering where all decisions regarding the allocation of shares in the offering are determined at the sole discretion of the issuer, and the involvement of a member in the offering is mandated under state law and limited solely to ministerial functions.October 18, 2005 Noel M. Gruber, Esq.Kennedy &
