An exemption is granted based on the following: (1) Name was not an MFP at the time the Contribution was made and was not involved in the solicitation of new municipal securities business; (2) the Firm took action once it became aware of the Contribution by voluntarily refraining from new State or its issuing authorities municipal securities business pending the outcome of the exemption request; (3) the Firm notified Name of his designation as an MFP and the accompanying restrictions; (4) the Firm has agreed to restrict Name's municipal securities activities, minimizing the potential for quid pro quo resulting from the Contribution; and (5) although a less weighty factor, the Contribution has been returned.
Exemptive relief is granted based on the following considerations: (1) Name was not an MFP at the time the Contribution was made and was not involved in the solicitation of new municipal securities business; (2) the Firm took action once it became aware of the Contribution by instituting a self-ban on new City municipal securities business; (3) the Firm notified Name of her designation as an MFP and the accompanying restrictions; (4) the Firm has agreed to establish information barriers to help ensure the segregation of information flow, minimizing the potential for quid pro quo resulting from the Contribution; (5) the Firm represents that it has corrected the technical political contributions database problems and has established new procedures for direct notification to legal and compliance personnel of additions to the Parent Management Committee; and (6) although the Contribution has not been returned, the Firm represents that reasonable efforts have been made to obtain the return of the Contribution.
Exemptive relief is granted based on the following: (1) Name was not an MFP at the time the Contribution was made and was not engaged in, and did not supervise, municipal securities business; (2) the Firm took action once it became aware of the Contribution by retaining outside counsel to review the proposed reorganization and the possibility of municipal securities business restrictions as a result of the Contribution; (3) the Firm notified Name that when the municipal activities of certain retail sales brokers and MFP’s become part of the Business Unit on Month Day, 2003, the Firm will consider her to be an MFP and her municipal securities business activities will be restricted as a result of her Contribution and of her responsibilities3; (4) the Firm has agreed to restrict Name’s municipal securities activities, minimizing the potential for a quid pro quo resulting from the Contribution; and (5) although a less weighty factor, the Contribution has been returned.
This request for exemptive relief is granted based on the contributions made being small in amount, in support of personal relationships, the Firm’s representation that the contributor will be restricted in his municipal securities activities and municipal securities compensation, the individual will be subject to a period of heightened supervision, and the return or reasonable attempt at the return of the contributions.
May 9, 2001
Mr. John W. Marcus
Chairman
PIBC Securities LLC
640 Fifth Avenue
New York, NY 10019
Re: Exemption Request from Fidelity Bonding Requirements
Dear Mr. Marcus:
I am responding to your letter of November 21, 2000, in which you request that PIBC Securities LLC ("PIBC") be exempt from the requirement to maintain a fidelity bond under NASD Rule 3020. Specifically, your
October 18, 2001Mr. William E. FloriaPresidentHouse of Securities Company12 West Church StreetFrederick, MD 21701Re: Exemption Request from Fidelity Bonding RequirementsDear Mr. Floria:This is in response to your September 6, 2001 letter, in which you request that House of Securities Company (the “Firm”) be exempt from the annual review and adjustment requirements of NASD Rule 3020(c)(1) because
Requirements of NASD Rule 2420 to broker/dealer arrangement to pay certain commissions and SEC Rule 12b-1 fees to accounts of various employee benefit plan customers.
A short interest rebate, under certain circumstances, may be paid to a non-member trust company as compensation for work performed in administering accounts.
A networking arrangement between a broker/dealer and a licensed insurance agency in which the non-member insurance agency receives commission payments is not subject to Rule 2420 if the arrangement is undertaken in reliance on an SEC no-action position on the registration requirements of the insurance agency as a result of the arrangement.
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.