REQUEST FOR COMMENT
Corporate Debt Securities
SUGGESTED ROUTING
KEY TOPICS
Suggested Routing
Corporate Finance
Legal and Compliance
Operations
Senior Management
Technology Trading and Market Making Training
Debt Securities
Operations
Rule 6200 Series
TRACE Rules
Transaction Reporting
Executive Summary
Currently, NASD
REQUEST FOR COMMENTSubordination AgreementsComment Period Expires November 26, 2004SUGGESTED ROUTINGKEY TOPICSLegal & ComplianceOperationsSenior ManagementAppendix D to the Net Capital RuleNet CapitalSEC Rule 15c3-1Subordination AgreementsSubordinated LoansExecutive SummaryIn 2002, NASD adopted a requirement that firms submitting subordination agreements to NASD staff for approval provide
SUGGESTED ROUTING
Senior Management
Corporate Finance
Institutional
Legal & Compliance
Municipal
Operations
Systems
Trading
Executive Summary
On April 11, 1994, The Nasdaq Stock Market, Inc., began operation of the Fixed Income Pricing SystemSM (FIPS®) for members trading highyield bonds. FIPS was created to facilitate the over-the-counter (OTC) trading of high
SUGGESTED ROUTING
Senior Management
Internal Audit
Legal & Compliance
Training
Executive Summary
Members must review and correct promptly, as needed, their settlement agreements with customers or other persons that contain confidentiality clauses that prohibit or discourage the customer or other person from disclosing the settlement terms (and the underlying facts of the dispute
INFORMATIONAL
Anti-Money Laundering CompliancePrograms
Effective date: December 31, 2002
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Operations
Registration
Senior Management
Compliance Programs
Money Laundering
Executive Summary
NASD has adopted amendments to NASD Rule 3011 (Anti-Money Laundering Compliance Program) to require each member to provide to
IMMEDIATE ACTION REQUIRED
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Senior Management
Accounting
Operations
Retail
Mutual Funds
Mutual Fund Breakpoints
Customer Refunds
Net Capital Compliance
Background
In late 2002, as a result of several routine examinations, NASD discovered that some members had
Every day at FINRA, we protect investors from misconduct, stop fraud and provide restitution to harmed customers. And we are successful—in part because customers and other members of the public provide information and crucial evidence during the course of an investigation.
The Firm Short Positions and Fails-to-Receive in Municipal Securities and Fixed Income – Fair Pricing sections of the 2023 Report on FINRA’s Examination and Risk Monitoring Program (the Report) informs member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations, including (1) regulatory obligations and related considerations, (2) findings and effective practices, and (3) additional resources.
The NASD Office of General Counsel Regulatory Policy and Oversight (OGC) publishes the Disciplinary Update to provide registered representatives with a summary sampling of recent disciplinary actions involving misconduct by registered representatives. The sample of disciplinary actions includes settled matters and decisions in litigated cases (National Adjudicatory Council (NAC) decisions and decisions of the Securities and Exchange Commission in NASD cases).
What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement? Change needs to happen as soon as possible, immediately to restore faith in the markets. To make these crooked markets somewhat fair to retail investors. FINRA is considering whether daily or weekly short interest position reporting would