Exemptive Letter to Christopher M. Wells, Proskauer Rose LLP
Exemptive Letter to Michael R. Modeski, OTC Link LLC
Exemptive relief is granted based on: representations that at the time of the contribution the individual was not employed by the firm and was not an MFP; the firm already had a significant business relationship with the state of whom the contribution recipient is an issuer official 9as defined); the firm has instituted information barriers on certain municipal business communications; the individual will be prohibited from the solicitation of certain new municipal business for a period of time.
Exemptive relief is granted based on: the representation that at the time of the contribution the individual was not an MFP (as defined); the firm already has a significant business relationship with the government entity of which the contribution recipient was considered to be an issuer official; the firm has instituted information barriers on certain municipal business communications; the individual will be prohibited from the solicitation of certain new municipal business for a period of time.
Exemptive relief is granted based on: the representation that at the time of the contribution the individual was not an MFP (as defined); the firm already has a significant business relationship with the governmental entities of which the contribution recipients were considered to be issuer officials; the firm has instituted information barriers on certain municipal business communications; the individual involved will be prohibited from the solicitation of certain new municipal business for a period of time.
Exemptive relief is granted based on: the representations that the contributions were made prior to employment; the individual did not engage in the solicitation of, or have involvement in, municipal securities business (as defined) for the prior six years; the firm had no knowledge of the contributions at the time they were made; the firm has established detailed and comprehensive compliance procedures and has developed information barriers surrounding the solicitation of certain municipal securities business.
Exemptive relief is granted based on: the representation that at the time of the contribution the individual had no connection to the firm’s municipal securities business, and it was not contemplated that, at the time of the contribution, he would be promoted and, thus, become a municipal finance professional (as defined); the firm has significant and long standing business relationships with the government entity of which the contribution recipient was an issuer official; the firm has established additional compliance processes about political contributions; the individual will not be involved in any way in municipal securities business with the state or any other governmental issuer business for which the contribution recipient is an issuer official.
<p>Further interpretive advice to members concerning the sale of hedge funds.</p>
Guidance regarding use of related performance information in sales material for private equity funds.
Placing limit orders in ECNs that comply with the ECN Display Alternative under the SEC's Order Handling Rules in order to affect the price of transactions effected through POSIT may constitute market manipulation in violation of the antifraud provisions of the securities laws and NASD rules.
